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Issues: Whether interference under Article 226 of the Constitution of India was warranted against the assessment order on the ground that the digital evidence was not shown to have been collected and relied upon in accordance with the Digital Evidence Investigation Manual and Section 65B of the Indian Evidence Act, 1872, or whether the petitioner should be relegated to the statutory appellate remedy.
Analysis: The challenge rested on alleged non-compliance with the Digital Evidence Investigation Manual and Section 65B of the Indian Evidence Act, 1872, but no specific breach was demonstrated and no such objection appeared to have been raised during the assessment proceedings. The dispute would require reappraisal of evidence, which is ordinarily not undertaken in writ jurisdiction. In these circumstances, the appropriate forum for examining the evidentiary controversy was the appellate authority, particularly when a statutory appeal was available.
Conclusion: Interference under Article 226 was declined and the petitioner was relegated to the statutory appellate remedy.