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The HC dismissed the writ petition challenging the assessment order framed under section 147 read with section 144, holding that the petition did not fall within the limited scope for writ jurisdiction due to the availability of efficacious alternative statutory remedies. Given the existence of disputed questions of fact and mixed questions of law, the court held that the appellate authority under the IT Act is the appropriate forum to address jurisdictional and substantive issues. The court emphasized that appeals and further remedies exist under the statute to challenge assessment orders, including second appeals against first appellate orders. The writ petition was dismissed as lacking merit, with all pending interlocutory applications also dismissed. The decision does not preclude statutory authorities from adjudicating the merits of issues if raised in appropriate proceedings.
The HC dismissed the writ petition challenging the assessment order framed under section 147 read with section 144, holding that the petition did not fall within the limited scope for writ jurisdiction due to the availability of efficacious alternative statutory remedies. Given the existence of disputed questions of fact and mixed questions of law, the court held that the appellate authority under the IT Act is the appropriate forum to address jurisdictional and substantive issues. The court emphasized that appeals and further remedies exist under the statute to challenge assessment orders, including second appeals against first appellate orders. The writ petition was dismissed as lacking merit, with all pending interlocutory applications also dismissed. The decision does not preclude statutory authorities from adjudicating the merits of issues if raised in appropriate proceedings.
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