This writ petition is disposed of preserving the rights of the writ petitioner to avail alternate remedy by way of a statutory revision under Section 264 of IT Act. Though obvious, it is made clear that all contentions raised by the writ petitioner are left open and can be raised before the statutory Appellate Authority. It is also made clear that such a course is being adopted as perusal of the impugned order and reply to the SCN reveals that it turns heavily on facts as already alluded to supra.