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TMI Blog2019 (7) TMI 1694X X X X Extracts X X X X X X X X Extracts X X X X ..... pproaching the statutory authority - HELD THAT:- Matter involves some fact finding exercise and the same can be effectively prosecuted before the competent authority under the statute, which cannot be a matter for discussion and finalization invoking the discretionary jurisdiction of this court under article 226 of the Constitution of India. No irregularity, much less any illegality, with regar ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in filing the appeal is hereby condoned and the appeal is heard finally. 3. The correctnesses and sustainability of the verdict passed by the learned single judge in (Precision Engineering v. Asst. CIT (No. 1) [2020] 427 ITR 198 (Chhattisgarh)) declining interference with regard to the challenge raised as to the reassessment proceedings under section 147 read with section 148 of the Income-tax ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sides, the learned single judge observed that, it was a matter which could be effectively challenged by approaching the statutory authority. Accordingly, the writ petition was dismissed, without prejudice, which has given rise to the present appeal. 7. The learned counsel for the appellant submits that the relegation of the appellant to move the statutory authority is not correct, in so far as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to the course ordered to be pursued by the learned single judge. The appeal fails and it is dismissed accordingly. However, we make it clear that we have not expressed anything with regard to the merit of the case. It is always open for the appellant to establish the merit of the case before the statutory authority, based on the facts and the relevant provisions of law. 10. It is further made ..... X X X X Extracts X X X X X X X X Extracts X X X X
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