Section 226(3) notice challenge: objections must be heard, a reasoned order passed, and the notice kept in abeyance.

A notice issued under Section 226(3) of the Income-tax Act was challenged, and the Court required the respondent to consider the petitioners' objections before acting on it. The respondent was directed to afford a personal hearing, hear the available partners of the firm, and pass a reasoned order within the stipulated time. Pending such consideration, the impugned notice was kept in abeyance.

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Issues: Whether the notice issued under Section 226(3) of the Income-tax Act, 1961 should be quashed, and whether the petitioners' representation against the notice required consideration with an opportunity of hearing.

Outcome: The writ petition was disposed of with a direction to the respondent to consider the petitioners' objections, afford personal hearing, hear the available partners of the firm, and pass a reasoned order within the time stipulated by the Court. The impugned notice was directed to be kept in abeyance pending such consideration.

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