Alternative remedy bars writ challenge to tax show-cause notice; parties must and raise defences before the assessing authority.

A writ challenge to a show-cause notice alleging tax liability on salary paid to employees working in India was not entertained because an alternative statutory remedy was available. The Court held that the proper course was to file a reply to the notice and raise all available defences before the Income-tax Officer, and it declined to consider new factual assertions first raised in writ proceedings. The High Court's view that the appellants should pursue the notice proceedings was affirmed.

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Issues: Whether the writ petition challenging the show-cause notice was maintainable in view of the availability of an alternative remedy, and whether the notice ought to be interfered with at the threshold.

Analysis: The challenge was directed against a show-cause notice alleging tax liability in respect of salary paid to employees working in India. The appellants had bypassed the notice and invoked writ jurisdiction. The Court held that the proper course was to file a reply to the notice and raise all available defences before the Income-tax Officer. It also declined to examine new factual assertions first raised before it.

Conclusion: The writ challenge was not entertained, and the High Court's view that the appellants should pursue the notice proceedings was affirmed.

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