Writ challenge to pre-assessment notices failed at show-cause stage as limitation could be examined by the assessing authority.

Writ petitions challenging pre-assessment notices were not entertained at the show-cause stage because the limitation objection could be raised before the assessing authority. Interference under Article 226 at the notice stage is exceptional and is exercised sparingly where the controversy can be examined in the statutory proceedings. Limitation in this context was treated as a mixed question of law and fact, suitable for decision by the issuing authority after considering the petitioners' objections and giving an opportunity of hearing. The petitioners were therefore left to pursue their objections before the assessing authority.

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Issues: Whether the writ petitions challenging the pre-assessment notices were maintainable at the show-cause stage on the ground that the notices were barred by limitation and without jurisdiction.

Analysis: The challenge was directed against pre-assessment notices and the objection of limitation could be raised before the assessing authority. Interference under Article 226 at the notice stage is an exception and is exercised sparingly, particularly where the controversy involves questions that can be examined in the statutory proceedings. Limitation in the present setting was treated as a mixed question of law and fact, which could appropriately be adjudicated by the authority issuing the notices after considering the petitioners' objections and affording an opportunity of hearing.

Conclusion: The writ petitions were not entertained at the show-cause stage and the petitioners were left to pursue their objections before the assessing authority.

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