https://www.taxtmi.com/caselaws?id=14542 Writ interference with a show-cause notice under section 263 of the Income-tax Act is ordinarily refused where the Commissioner has recorded prima facie satisfaction that the assessment order is erroneous and prejudicial to the interests of the Revenue. At the notice stage, the court will not examine the intrinsic merits of the controversy unless an exceptional case for intervention is shown. On the facts noted, the Commissioner had recorded the necessary foundational satisfaction and the assessee had already replied, so interference under articles 226 and 227 was declined. en-us Thu, 24 Aug 2000 00:00:00 +0530 Fri, 17 Jul 2009 11:06:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=14542 Writ interference with a show-cause notice under section 263 of the Income-tax Act is ordinarily refused where the Commissioner has recorded prima facie satisfaction that the assessment order is erroneous and prejudicial to the interests of the Revenue. At the notice stage, the court will not examine the intrinsic merits of the controversy unless an exceptional case for intervention is shown. On the facts noted, the Commissioner had recorded the necessary foundational satisfaction and the assessee had already replied, so interference under articles 226 and 227 was declined. Case-Laws Income Tax Thu, 24 Aug 2000 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=14542