Writ jurisdiction should not substitute findings of an AO with its own: HC

Debraj Dealers Private Limited Vs Union of India And Ors (Calcutta High Court) HC held that Writ Court should not in exercise of its writ jurisdiction should substitute the findings of an assessing officer in his order with its own. In addition, I am of the considered view that the order under Section 148A(d) of the Income Tax Act, 1961 in itself is not a final assessment order or demand and petitioner will still have scope of making out a case on merit for dropping the reassessment proceeding after issuance of notice under Section 148 of the Act subsequent to the order under Section 148A(d) o...