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Section 260A of the Income-tax Act, 1961 - High Court - Appeal to - Where in a writ, question of jurisdiction had been disposed of by High Court but on special leave petition on going through papers, it was found that foundational facts were required to be established which could not have been done by way of writ petition, assessee would be relegated to adopt proceedings, which were pending, as of date, before various authorities under Act The issue in the instant special leave petition was concerned with the application of the principle of transfer pricing. In the case of the assessee, notice was issued under section 148 for some of the assessment years. Held that on going through the papers, it was found that facts were required to be established which could not have been done by way of writ petition, for the aforestated reasons, the assessee would be relegated to adopt proceedings, which were pending, as of date, before the various authorities under the Act. The authorities were to be directed to expeditiously dispose of pending proceedings as early as possible. If the petitioner-assessee herein was aggrieved by the orders passed by any of these authorities, it would have to exhaust the statutory remedy provided under the Act. Each of the authorities would decide the matter uninfluenced by any of the observations made in the impugned . S. Ganesh, Aashish Gupta and Suresh A. Shroff for the Appellant. R.P. Bhatt, D.K. Singh, Arjun Krishnan and B.V. Balaram Das, for the Respondent. ORDER 1. The issue in this special leave petition concerns the application of the principle of…

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