https://www.taxtmi.com/caselaws?id=49347 Article 226 writ jurisdiction cannot be used to pre-empt statutory tax remedies: challenges to notices and assessments are ordinarily for the Income-tax Officer to decide and writs are not maintainable as substitutes for those remedies. A limitation plea must be raised and adjudicated before the tax authorities and cannot be developed afresh in writ proceedings under the circumstances. Contentions that an assessment is merely protective or that others were taxed on the same transactions are factual/evidential matters lacking sworn support and are for the Income-tax Officer to examine; they do not justify setting aside assessment by writ. en-us Wed, 05 Aug 1964 00:00:00 +0530 Fri, 22 Aug 2014 12:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49347 Article 226 writ jurisdiction cannot be used to pre-empt statutory tax remedies: challenges to notices and assessments are ordinarily for the Income-tax Officer to decide and writs are not maintainable as substitutes for those remedies. A limitation plea must be raised and adjudicated before the tax authorities and cannot be developed afresh in writ proceedings under the circumstances. Contentions that an assessment is merely protective or that others were taxed on the same transactions are factual/evidential matters lacking sworn support and are for the Income-tax Officer to examine; they do not justify setting aside assessment by writ. Case-Laws Income Tax Wed, 05 Aug 1964 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49347