On appeal against the single judge order the Court held that the grounds raised namely there had been violation of the principles of natural justice,  there was total non-application of mind, and  that the addition made under section 69A of the Act was uncalled for, were all matters where the factual matrix needed to be adjudicated threadbare. Such an exercise could not be done by a writ court and should not be permitted to be done. Court also observed that the observation contained in the single judge’s order on that aspect needed to be eschewed. The sweeping observations and remarks were not called for especially when the system had been implemented and assessees throughout the country had changed from manual procedure to e-procedure. The order of the single judge and all the observations and findings regarding the effectiveness of the e-governance implemented by the Department and the observations and findings rendered in the order touching upon the merits of the assessment were set aside. (AY.2017-18)