The Special Court discharged the responded. The revenue has filed revision petitions before the High Court. Dismissing the Revision petitions the Court held that,  the only circumstance relied on by the complainant in support of the alleged charges was that, during the search action, certain unaccounted loan transactions with several persons or entities were detected and it was ascertained that the respondent had advanced huge amount of loan to these persons or entities and the unaccounted financial transactions were not disclosed in his returns of income for the relevant years and that the respondent had received huge amount of interest on the unaccounted loan. These allegations, even if accepted as true, did not prima facie constitute offences under section 276C(1) of the Act. Tax, penalty or interest could be evaded provided tax or penalty is chargeable or imposable in respect such transactions. That the complaints were lodged by the authorized officer directly before the special court and the records of the proceedings indicated that on receiving the complaints, the special court straightaway issued summons to the accused without taking cognizance of any of the offences. As the prosecution initiated against the respondent was bad in law and contrary to the procedure prescribed under the Code of Criminal Procedure and the provisions of the Income-tax Act, the revision petitions are liable to be dismissed. Court also held that the Special Court gets jurisdiction only on complaint by competent authority, Special Court has no original jurisdiction to take cognizance of the offences under Chapter XXII of the Income tax Act unless the accused is committed for trail.   Relied,   D.K. Shivkumar v. ITO (2020) 421 ITR 529 (Karn.)(HC).