1992 (1) TMI 56

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....A J. -Against a notice issued under section 226(3) of the Income-tax Act, the petitioner came to this court by way of a petition which was disposed of by our order dated December 17, 1991. Tile objection raised before the court on that occasion was that no amount was payable by the petitioner to Surendra Chand Bansal and that no loan was ever taken by him from the latter. In support, the petitione....

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....k that the petitioner has an effective alternative remedy available to it by way of revision under section 264 of the Income-tax Act. Indeed, having regard to the nature of the issues involved in the case and the factual controversy arising for consideration, we think that the remedy by way of revision would be more appropriate. The Commissioner can consider all the points sought to be raised here....