9911796707
TMI Blog2000 (8) TMI 36X X X X Extracts X X X X X X X X Extracts X X X X ..... of Income-tax issued notice dated May 10, 2000, under section 263 of the Income-tax Act, 1961, calling upon the petitioner to file clarification supported with the details. It is this order of the Commissioner which has been challenged by the petitioner in this writ petition, filed under articles 226 and 227 of the Constitution of India. In view of the order which I propose to pass in this writ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... judicial to the interests of the Revenue. He attempted to address on the merits of the case to demonstrate that the finding arrived at by the Commissioner of Income-tax while calling upon the petitioner to file its reply under section 263 of the Income-tax Act is unsustainable. In support of his submission, Mr. Nema has placed reliance on a large number of authorities. Mr. A. P. Shrivastava, howev ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... icer is erroneous and prejudicial to the interests of the Revenue. The Commissioner while calling upon the petitioner to submit reply has recorded such a finding. It is well settled that this court while exercising its power under articles 226 and 227 of the Constitution of India does not interfere with the show-cause notice unless an exceptional case is made out. As held earlier, foundational f ..... X X X X Extracts X X X X X X X X Extracts X X X X
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