Can writ petition be dismissed on the sole ground that appellant had a right of reply to show cause notice

M/s. WABCO India Limited Vs DCIT (Madras High Court) On a perusal of the aforesaid show cause notice, it is patently clear that it was accepted that there was transaction between Clayton Dewandre and WABCO, Singapore. In the show cause notice, it was alleged that scrutiny assessment of Clayton Dewandre established that the place of effective management was the United Kingdom, but Clayton Dewandre had deliberately made a paper transaction to obtain undue benefit of the Indo Netherlands treaty. Based on such finding, a draft assessment order had been issued giving rise to possibility of tax liab...