https://www.taxtmi.com/caselaws?id=357613 Sanction for prosecution under the Income-tax Act was not quashed in writ jurisdiction because the challenge turned on disputed factual questions of reasonable cause and alleged non-compliance with departmental instructions. Grant of sanction was treated as an administrative, prima facie determination that the facts disclose an offence, not a forum for pre-trial adjudication of the complaint's merits. The writ court therefore declined to act as an appellate body over the sanction order, leaving the petitioners to raise their factual and legal defences, including issues relating to summoning and cognizance, before the criminal court. en-us Mon, 12 Mar 2018 00:00:00 +0530 Fri, 22 Jun 2018 16:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=357613 Sanction for prosecution under the Income-tax Act was not quashed in writ jurisdiction because the challenge turned on disputed factual questions of reasonable cause and alleged non-compliance with departmental instructions. Grant of sanction was treated as an administrative, prima facie determination that the facts disclose an offence, not a forum for pre-trial adjudication of the complaint's merits. The writ court therefore declined to act as an appellate body over the sanction order, leaving the petitioners to raise their factual and legal defences, including issues relating to summoning and cognizance, before the criminal court. Case-Laws Income Tax Mon, 12 Mar 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=357613