https://www.taxtmi.com/caselaws?id=409622 The Court dismissed the writ petition challenging the notice under Section 148 of the Income Tax Act and the order disposing of objections. It held that disputed facts and circumstances cannot be adjudicated in a writ proceeding under Article 226 of the Constitution of India. The Court emphasized that deeming fictions under the IT Act cannot be applied to beneficial provisions. The reasons for disallowances were upheld, and the Court ruled that such disallowances needed to be added back to taxable income. The writ petition was dismissed without costs, and the connected miscellaneous petition was closed. en-us Wed, 30 Jun 2021 00:00:00 +0530 Tue, 13 Jul 2021 10:36:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=409622 The Court dismissed the writ petition challenging the notice under Section 148 of the Income Tax Act and the order disposing of objections. It held that disputed facts and circumstances cannot be adjudicated in a writ proceeding under Article 226 of the Constitution of India. The Court emphasized that deeming fictions under the IT Act cannot be applied to beneficial provisions. The reasons for disallowances were upheld, and the Court ruled that such disallowances needed to be added back to taxable income. The writ petition was dismissed without costs, and the connected miscellaneous petition was closed. Case-Laws Income Tax Wed, 30 Jun 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=409622