Penalty under section 271(1)(c) deleted where income was disclosed in section 153A returns and remaining additions were only estimated or computationa...
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Writ jurisdiction under Article 226 is ordinarily not exercised where an efficacious statutory appeal is available, unless there is breach of natural justice, lack of jurisdiction, or a challenge to vires. In this GST dispute, the petitioners did not challenge the show cause notice at the outset and raised limitation and jurisdiction objections only after the adjudication order. The Court held those issues could be effectively raised before the appellate authority under Section 107, declined to examine the merits, and granted liberty to pursue the statutory appeal, leaving all questions on limitation and jurisdiction open.
Writ jurisdiction under Article 226 is ordinarily not exercised where an efficacious statutory appeal is available, unless there is breach of natural justice, lack of jurisdiction, or a challenge to vires. In this GST dispute, the petitioners did not challenge the show cause notice at the outset and raised limitation and jurisdiction objections only after the adjudication order. The Court held those issues could be effectively raised before the appellate authority under Section 107, declined to examine the merits, and granted liberty to pursue the statutory appeal, leaving all questions on limitation and jurisdiction open.
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