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Issues:
1. Allegations of overstepping the limits prescribed by the Income-tax Act by the Income-tax Officer and the Inspecting Assistant Commissioner. 2. Allegations of personal bias, misuse of power, and harassment against the officers. 3. Examination of the procedural irregularities and alleged mala fides in the assessment proceedings. 4. Request for a writ of mandamus to direct the officers to adhere to the statutory procedure. Analysis: Issue 1: The petitioner sought a writ of mandamus to restrain the Income-tax Officer and the Inspecting Assistant Commissioner from exceeding the bounds set by the Income-tax Act during the assessment process. The petitioner alleged that the officers had demanded account books for an excessive period of eight years, contrary to the Act's provision limiting it to three years preceding the previous year. The court noted the unreasonable nature of the demand and observed that the officer had potentially overstepped the legal boundaries in the pursuit of "efficient administration." Issue 2: The petitioner accused the officers of personal bias and misuse of power, claiming that the assessment proceedings were influenced by ill-feelings and misunderstandings between the officers and the petitioner's father. The court examined affidavits and counter-affidavits filed by the officers, denying the allegations of bias and asserting that they acted within the confines of the law. The court found insufficient evidence to prove the allegations of mala fides against the officers. Issue 3: The court scrutinized the procedural irregularities in the assessment proceedings, including the short notice given to produce account books and the issuance of notices to unrelated parties. While the petitioner's counsel argued that these actions demonstrated the arbitrary and capricious nature of the proceedings, the court found no substantial grounds to support the allegations of mala fides. The court emphasized the need for officers to act reasonably and within the prescribed legal limits. Issue 4: Regarding the relief sought by the petitioner through the writ petition, the court deliberated on the scope of granting declaratory relief in such cases. The petitioner aimed to ensure that future proceedings adhere strictly to the statutory procedure. However, the court referred to precedents where it was held that writs should not be used for declaratory relief. It highlighted the availability of appellate avenues within the Income-tax Act for the petitioner to address any grievances regarding the assessment process. Consequently, the court dismissed the writ petition, stating that the relief sought was not suitable for a writ application. In conclusion, the court dismissed the petition, emphasizing that the relief sought was not appropriate for a writ petition and that the petitioner could pursue remedies through the established hierarchy of tribunals under the Income-tax Act.
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