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TMI Blog2018 (7) TMI 1856X X X X Extracts X X X X X X X X Extracts X X X X ..... sidered the overall circumstances of the case. On merits, the petitioner was unsuccessful before the three statutory authorities. Therefore, as far as the appreciation of facts and application of law is concerned, there is no question of interference under Article 226 of the Constitution. In any event, the narrow compass within which this Court is called upon to exercise jurisdiction under Article ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... penalty based upon the findings of the Assessing Officer (AO) that one Sh. Pradeep Kumar Bansal [hereafter "Sh. Bansal"] had provided accommodation entries and that the credit claimed was not genuine. Its appeal before the CIT(A) was unsuccessful as was its further appeal to the ITAT. It, therefore, approached the ITAT again, under Section 254(2) of the Income Tax Act, 1961 [hereafter "the 1961 A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rned, there is no question of interference under Article 226 of the Constitution. In any event, the narrow compass within which this Court is called upon to exercise jurisdiction under Article 226 is to consider whether the ITAT's refusal to rectify its previous order (which was based upon the merits of the matter, including the allegation of denial of natural justice), was illegal. The Court is ..... X X X X Extracts X X X X X X X X Extracts X X X X
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