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Appeal under Letters Patent against the judgment of Chandra Reddi J. dismissing applications under Article 226 of the Constitution regarding enforcement of orders of assessment of excess profits tax and income-tax. Invocation of jurisdiction under Article 226 based on alleged violation of constitutional guarantees, particularly Article 14. Analysis: The judgment pertains to appeals under the Letters Patent against the dismissal of applications under Article 226 of the Constitution by Chandra Reddi J. The relief sought in all petitions was related to proceedings for the enforcement of orders of assessment of excess profits tax and income-tax. The petitioners had been assessed for several years and had appealed to the Appellate Assistant Commissioner of Income-tax. The applications were filed to challenge the orders while the appeals were pending, seemingly due to actions taken by the Income-tax authorities to collect the imposed tax. The primary ground for invoking jurisdiction under Article 226 was the alleged violation of constitutional guarantees, particularly Article 14. The attack on the procedural provisions of the Income-tax Act was based on three main arguments. Firstly, it was contended that Section 5(8) of the Income-tax Act affected the independence and impartiality of assessing officers, thus violating Article 14. However, the court found that Section 5(8) did not necessarily involve specific orders or directions in individual cases but rather general guidance for officers. The court held that even if such directions were issued, they did not infringe the principle of equality before the law. Secondly, it was argued that the non-disclosure of material by the Income-tax Officer for assessments was inconsistent with Article 14. The court disagreed, stating that the officer's wide powers to gather material without the assessee's knowledge were common in taxing statutes. The assessee had the right to appeal through prescribed tribunals, rendering further attack on the proceedings on this ground unnecessary. Lastly, the contention that the appellants were denied the right to be heard regarding the evidence used for assessment was addressed. The court noted that the focus was on whether the prescribed procedure violated constitutional rights, not on introducing new evidentiary provisions. The appellants' failure to challenge the actual orders passed against them, which were subject to appeals, was highlighted. Ultimately, the court found no merit in the contentions raised and dismissed the appeals. In conclusion, the judgment thoroughly analyzed the grounds raised by the appellants regarding the procedural provisions of the Income-tax Act and their alleged violation of constitutional guarantees, particularly Article 14. The court's detailed examination of each argument and its application of legal principles underscored the dismissal of the appeals.
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