Dismissing the petition the Court held that , the writ petition  against show cause notice is  premature and not maintainable. The proceeding was only in the form of a show-cause notice and therefore, the assessee had to respond to it and it could not be questioned in a writ petition. However, there was no necessity for the authority to issue a show-cause notice before granting an order of sanction as it was an administrative act. Nevertheless, the Principal Director (Investigation) had issued the show-cause notice with a view to provide an opportunity to the assessee, of which he had to avail. Hence, the show-cause notice need not be interfered with in a writ petition under article 226 of the Constitution. The Principal Director (Investigation) was one of the authorities enumerated in the proviso to S.279(1) and therefore, had sufficient jurisdiction to issue the show-cause notice under S.276C(1) . (AY.2017-18)