Writ petitions against show cause notices are ordinarily premature where an effective reply can still be filed before the authority.

Writ jurisdiction is ordinarily not invoked against a mere show cause notice where the affected party still has an effective opportunity to respond before the competent authority; the petitioners were therefore relegated to raise all submissions before that authority, which was to decide the matter on merits and in accordance with law. The challenge to the attachment orders and seizure of books of account did not survive after the authority stated that those orders had been withdrawn, with liberty to proceed afresh under the applicable provisions, and the seized materials were directed to be returned after copying.

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Issues: (i) Whether a writ petition challenging a show cause notice was maintainable at the stage of notice; (ii) whether the impugned attachment orders and seizure of books of account survived after the authority withdrew them.

Issue (i): Whether a writ petition challenging a show cause notice was maintainable at the stage of notice.

Analysis: The challenge was directed against a show cause notice, and the petitioners were still to place their submissions before the issuing authority. The Court applied the settled rule that writ jurisdiction is ordinarily not invoked at the stage of a mere show cause notice when an effective opportunity remains available before the competent authority. The petitioners were relegated to raise all contentions before that authority, which was directed to decide the matter on merits and in accordance with law.

Conclusion: The writ petition was not entertained against the show cause notice and was dismissed to that extent.

Issue (ii): Whether the impugned attachment orders and seizure of books of account survived after the authority withdrew them.

Analysis: The respondent authority stated that the attachment orders and the orders seizing the books of account were withdrawn, while reserving liberty to proceed afresh in accordance with law under the relevant statutory provisions. In view of that statement, no further adjudication on those prayers was required, and the seized materials were directed to be returned after copying.

Conclusion: The challenge to the attachment and seizure orders did not survive and stood disposed of on withdrawal.

Final Conclusion: The petition was declined on the show cause notice challenge, while the attachment and seizure-related prayers stood disposed of because the impugned orders were withdrawn and the materials were directed to be returned.

Ratio Decidendi: A writ petition is ordinarily not entertained at the stage of a show cause notice when the competent authority has yet to decide the matter and the petitioner has an adequate opportunity to respond before that authority.

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