Civil court jurisdiction is barred under the Income-tax Act despite allegations of mala fides in Chapter XX-A proceedings.

Section 293 of the Income-tax Act, 1961 bars civil court jurisdiction in matters covered by the Act, including proceedings under Chapter XX-A. Allegations of mala fides against income-tax do not create jurisdiction where the statute expressly excludes it. A civil suit challenging such proceedings therefore cannot be entertained on the basis of alleged bad faith, because statutory exclusion prevails over the pleaded allegations.

---

---

Issues: Whether allegations of mala fides could confer jurisdiction on a civil court where such jurisdiction was expressly barred by statute in proceedings under Chapter XX-A of the Income-tax Act, 1961.

Analysis: Section 293 of the Income-tax Act, 1961 expressly bars the jurisdiction of civil courts in matters covered by the Act. The proceedings challenged in the civil suit arose under Chapter XX-A of the Act. Mere allegations against an income-tax could not create jurisdiction where the statute had taken it away. The civil court therefore could not entertain the suit on the basis of alleged mala fides.

Conclusion: The civil court had no jurisdiction, and allegations of mala fides did not confer any jurisdiction on it.

---