Writ interference in income-tax proceedings limited to jurisdictional defects; factual disputes alone do not justify quashing notice.

Writ interference under Article 226 is ordinarily available only where income-tax notice or proceedings are without jurisdiction or fundamentally void; a mere dispute over the factual correctness of material relied upon, or an allegation that the reply was not properly considered, does not by itself justify quashing. The Income-tax Act provides an adequate statutory remedy if the eventual assessment is contrary to facts or the record. On that basis, the challenge to the notice and proceedings was rejected.

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Issues: Whether the notice and proceedings initiated by the Assessing Officer under the Income-tax Act could be quashed in writ jurisdiction on the ground that the petitioner disputed the factual correctness of the material relied upon and alleged non-consideration of the reply.

Analysis: The Court held that interference under Article 226 is ordinarily warranted only where the notice or proceedings are without jurisdiction or fundamentally void. A mere dispute as to factual correctness, or the contention that the material before the Assessing Officer does not tally with the petitioner's version, does not by itself justify writ intervention. The statutory framework under the Income-tax Act provides an adequate mechanism for redress if the assessment order is ultimately found to be contrary to facts or material on record.

Conclusion: The challenge to the notice and proceedings was rejected, and the writ petition was dismissed.

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