Income Tax Assessment Order Challenge Fails Due to Limitation Issues and DIN Requirement Dispute

The HC declined to entertain a writ petition challenging an assessment order on grounds of limitation and absence of Digital Identification Number (DIN). The court held that limitation involves mixed questions of fact and law unsuitable for summary determination on affidavits alone. Regarding the DIN issue, the court noted that the Supreme Court had stayed a similar ruling in the Tata Medical Center Trust case. Following Bank of Baroda v. Farooq Ali Khan, the HC emphasized that statutory tribunals are constituted to determine questions of law and fact, and courts should not substitute themselves as decision-making authorities during judicial review. The petition was dismissed as non-maintainable since alternative and efficacious remedies remained available to the petitioner. .....

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