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    Section 153C jurisdiction fails for pre-block year and post-2021 initiation, quashing assessments under search provisions.
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      Writ interference despite an alternative statutory remedy is...

      Alternative remedy limits writ interference when natural justice complaints and penalty competence turn on factual adjudication issues.

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      GSTJuly 11, 2026Case LawsHC
      Writ interference despite an alternative statutory remedy is confined to cases of patent jurisdictional defect or manifest breach of natural justice. Complaints that the reply was inadequately considered, hearing notices were not served, a statement was coerced and later retracted, or cross-examination was denied were treated as issues of factual appraisal or merits for the appellate forum, so the writ was not entertained and the petitioner was left to the statutory appeal. The Court also accepted that the proper officer conducting Section 73 or 74 adjudication can impose consequential penalty under Section 122 in the same proceeding, without separate penalty proceedings, and rejected the competence challenge.

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      ActsIncome Tax