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Issues:
Validity of notices issued by the ITO under s. 226(3) of the I.T. Act, 1961 to the U.P. State Warehousing Corporation for rent due from certain godowns, ownership dispute over the godowns between the petitioner and the Corporation, jurisdiction of the ITO in issuing the notices, estoppel claim by the petitioner, conflicting claims about ownership by different family members and concerns, payment of rent to the ITO, and the appropriateness of deciding complex property title issues in a writ petition. Analysis: The judgment pertains to a writ petition challenging the validity of notices issued by the ITO under s. 226(3) of the I.T. Act, 1961 to the U.P. State Warehousing Corporation for rent due from certain godowns. The petitioner claimed ownership of the godowns and contended that the rent was due to her, not to other assessees named in the notices. The respondent-Corporation disputed the ownership claim, stating negotiations occurred with a different family firm. The court noted the dispute over the landlord's identity and the lack of clarity on possession admission by the Corporation. The petitioner's estoppel claim based on the Indian Evidence Act was contingent on proving the Corporation was initially admitted as a tenant. The court highlighted the need to establish facts before invoking estoppel. The ITO's actions were based on prima facie evidence from the Corporation, with ongoing inquiries. The court emphasized that complex property title disputes were unsuitable for resolution in a writ petition. The petitioner's rights to present her case to the ITO and pursue legal action were acknowledged, indicating no prejudice to her claim due to the notices issued. Regarding rent payment to the ITO, the court clarified that such payments would discharge the payer's liability only to the named assessees in the notices. If rent was owed to the petitioner but paid to the ITO incorrectly, the petitioner could still seek recovery from the Corporation. Ultimately, the court dismissed the writ petition, emphasizing the inability to interfere in the s. 226(3) proceedings and highlighting the petitioner's recourse through legal avenues for rent recovery. In conclusion, the judgment addresses the complex ownership dispute over the godowns, jurisdictional issues related to the notices issued by the ITO, and the limitations of resolving intricate property title matters through a writ petition. The court's decision underscores the importance of factual clarity, legal procedures for rent payment, and the petitioner's rights to pursue remedies outside the writ jurisdiction.
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