Case Studies of Landmark Income Tax Judgments | TaxPundit

In this landmark judgment, the Supreme Court reinforced the doctrine of exhaustion of alternative remedies in tax matters. The Court overturned the High Court’s decision to quash reassessment proceedings under Section 148 of the Income Tax Act, holding that the assessee should have first pursued the statutory appeal before the Commissioner of Income Tax (Appeals) rather than directly invoking writ jurisdiction. The ruling underscores that writ petitions under Article 226 should be exceptional, not routine, in tax disputes where the statute provides a specialized appellate mechanism. The Court allowed the Revenue’s appeal but granted the assessee liberty to file a statutory appeal within four weeks, with condonation of limitation.