Writ interference with Section 148A(d) order refused where no natural justice breach, jurisdictional defect, or procedural irregularity was shown.

The Calcutta HC declined writ interference with an order under Section 148A(d) of the Income-tax Act, holding that the order had been passed after due consideration and disclosed no breach of natural justice, jurisdictional defect, or procedural irregularity. Mere disagreement with the reasoning recorded in the order was not enough to invoke Article 226 jurisdiction. The existence of the final assessment order under Section 147, which was stated to be appealable and was not challenged in the writ petition, further supported non-interference. The writ petition was rejected.

---

---

Issues: Whether the impugned order under Section 148A(d) of the Income-tax Act, 1961 called for interference in writ jurisdiction on the grounds of violation of natural justice, lack of jurisdiction, or procedural irregularity.

Analysis: The order was found to have been passed after due consideration and without any breach of natural justice, jurisdictional defect, or procedural irregularity. Mere dissatisfaction with the reasoning recorded in the order was held not to justify invocation of constitutional writ jurisdiction under Article 226 of the Constitution of India. The existence of the final assessment order under Section 147, which was stated to be appealable and not under challenge in the writ petition, also supported non-interference.

Conclusion: Interference was declined and the writ petition was rejected.

---