N.K. Jain J.

1. The petitioner, by this petition under Article 226/227 of the Constitution of India, seeks issuance of an appropriate writ to quash the proceedings initiated by respondent No. 2--Inspecting Assistant Commissioner of Income-tax, Acquisition Range, Bhopal--under Section 269C of the Income-tax Act, 1961 (for short "the Act").

2. Right at the threshold it may be noted that the petitioner has come at the stage of issuance of show-cause notice. As a general rule, this court does not interfere at that preliminary stage of issuance of notice and the noticee is left free to contest the notice before the authority concerned and seek other remedies by way of appeal and revision, etc., as may be available under the law. However, in the instant case, what is challenged is the very jurisdiction of the competent authority to issue the impugned notice. Further, the way and manner in which proceedings in the case have been conducted by the successive competent authorities, also call for judicial review of those proceedings by this court under Article 227.

3. A few relevant facts as unfolded by the pleadings and the documents of the parties are these :

4. The petitioner along wit