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HC dismissed the writ petition challenging a tax show cause notice, holding that allegations of fraud or misstatement need not precisely mirror statutory language to invoke extended limitation under Section 74. The court found the notice's allegations sufficiently substantive and non-supply of a specific document does not automatically vitiate proceedings. The petitioner retains right to raise substantive arguments in appellate proceedings, with the dismissal focusing on procedural maintainability of the writ petition under Article 226. The court explicitly preserved the petitioner's right to contest merits before the appellate authority.
HC dismissed the writ petition challenging a tax show cause notice, holding that allegations of fraud or misstatement need not precisely mirror statutory language to invoke extended limitation under Section 74. The court found the notice's allegations sufficiently substantive and non-supply of a specific document does not automatically vitiate proceedings. The petitioner retains right to raise substantive arguments in appellate proceedings, with the dismissal focusing on procedural maintainability of the writ petition under Article 226. The court explicitly preserved the petitioner's right to contest merits before the appellate authority.
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