Show cause proceeding cannot be scuttled by filing a writ petition if it is not without jurisdiction

B. Somasundaram Vs JCIT (Madras High Court) Petitioner challenged the notice issued u/s 271D for for violation of Sec 269SS of IT Act. Petitioner contended that already a regular assessment order has been passed wherein, proposals were made for imposing penalty u/s 270A, 271A, 271B & 271AAC. Assessment order was later revised by invoking Sect 148 and another Assessment order has been passed, wherein, there is no proposal for imposing any penalty. Since the notice is vague, proposing imposition of penalty u/s 271D without any merits was questioned. Reliance was placed on the following decis...