Dismissing the petition against the order of single judge the  Court held that  ; The observations made by the single judge in the judgment under challenge would stand confined to consideration of the question whether interference was to be made by the court at the notice stage or not. In other words, the observations made by the single judge as to the scope of the relevant provisions of law would not be a bar to the appellate authority to consider the merits of the appeal including questions of law and of fact. It was open to the assessee to agitate all such aspects, both factual and legal, before the appellate authority and if they were raised, they should be considered untrammeled by the observations made by the single judge in the judgment under challenge.   Judgement in  Precision engineering v. ACIT (NO. 2) (2020) 427 ITR 258 (Chhattisgarh) distinguished.  ( AY.2012-13)