(1.) Two questions are raised by this writ petition. The first relates to the true meaning of the word "information" in section 147(b) of the Income-Tax Act, 1961 (hereinafter called "the Act" in short). This has received enough attention in judicial decisions to produce a conflict between them. The resulting uncertainty makes further discussion necessary. The second is so fundamental as to require careful consideration to reach a definitive conclusion. It is this :-Can the writ Court refuse to grant the relief to a petitioner on such grounds as (a) his conduct, or (b) he has not suffered any injustice, or (c) that the grant of the relief to him would result in injustice.
(2.) The petition raising these questions is filed by the petitioner who belonged to the former Indian Civil Service was a former Chief Justice of a High Court and is now a retired Judge of the Supreme Court on the following facts :-
(3.) The petitioner prays that the abovementioned notice under section 148 of the Act be quashed. His learned counsel Shri N. D. Karkhanis assisted by Shri S. C. Manchanda supported the petition on the following grounds :-