Writ jurisdiction and property sale timing: reassessment orders were left undisturbed, with the assessee directed to statutory appeal.

Writ interference was declined where the dispute over reassessment depended on contested facts about whether property sales had been concluded earlier. Unregistered agreements and bank transactions were found insufficient to prove a completed prior sale, and the alleged timing of the transaction could not be resolved in writ jurisdiction. The Court also noted that an agreement for sale of immovable property required registration under Section 17(1)(g) of the Registration Act, 1908. As an efficacious statutory appeal was available under the Income-tax Act, 1961, the assessee was relegated to the appellate remedy and the assessment orders were left undisturbed.

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Issues: Whether the writ petitions challenging the reassessment orders deserved interference in view of the petitioner's claim that the property sale had been concluded earlier and the consequent dispute on valuation and capital gains.

Analysis: The claim that the sales had been negotiated and partly paid during the lifetime of the petitioner's father was not supported by any concluded or registered agreement. The materials showed only unregistered agreements and bank transactions, which were insufficient to establish that the impugned property sales had been finally concluded on the earlier date claimed. The dispute turned on factual controversies regarding the existence and timing of the alleged prior agreement, which were not suitable for determination in writ jurisdiction. In addition, the petitioner had an efficacious statutory appeal under the Income-tax Act, 1961. The Court also noted that an agreement for sale of immovable property was required to be registered under Section 17(1)(g) of the Registration Act, 1908.

Conclusion: No interference with the assessment orders was warranted, and the petitioner was relegated to the statutory appellate remedy.

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