SUSANTA CHATTERJEE, J. ( 1 ) THE present rule was issued on March 15, 979, at the instance of the writ petitioner, Messrs. India Foils Limited, praying, inter alia, for an appropriate writ of mandamus commanding the respondent to deal with and dispose of the applications made under Section 220 (6) of the Income-tax Act and/or stay of realization of demands for the years 1973-74, 1974-75 and 1975-76 and not to treat the petitioner as a defaulter till the disposal of the appeals pending before the appellate authorities and also to command the respondents to rescind and/or withdraw three notices dated February 27, 1979, issued under Section 221 (1) of the Income-tax Act, one each relating to the assessment years 1973-74, 1974-75 and 1975-76 and the order contained in the letter dated November 18, 1978, relating to the assessment year 1973-74 and the order contained in the letter dated February 27, 1979, relating to the assessment years 1974-75 and 1975-76 and all proceedings relating thereto and/or thereunder. It is contended that respondent No. 1, the Inspecting Assistant Commissioner of Income-tax, Foreign Companies, Range-II, failed to exercise his judicial discretion vested in him in accordance with law and his refusal to stay realization was vitiated by failure to consider the proper and relevant matters and taking into account irrelevant and extraneous considerations. It is further contended that the alleged reasons for the refusal to stay the realization of the demand, viz. , the need for collection of demand for the purpose of budget, does not constitute any valid material which can be taken into account for the purpose of exercising the power vested in it under the law. The decision of respondent No. 1 as such in refusing to stay the realization of the demand is illegal and invalid. It is alleged that respondent No. 1, while refusing to stay realization of the demand, acted contrary to law and under Section 220 (6) of the Income-tax Act in dealing with the application for stay of realization of demands till the disposal of the appeals, respondent No. 1 must act judicially and must exercise his discretion accordingly. It is alleged that respondent No. 1, while refusing to stay realization of the demand, acted contrary to law and under Section 220 (6) of the Income-tax Act in dealing with the application for stay of realization of demands till the disposal of the appeals, respondent No. 1 must act judicially and must exercise his discretion accordingly. The petitioner has tried to make out a case that respondent No. 1 has not dealt with or disposed of the applications made by the petitioner for stay of realization of demands for the assessment years as aforesaid in accordance with law and the impugned orders are bad in law and respondent No. 1 has no power, authority and/or jurisdiction to issue the notices under Section 221 (1) of the Act for the said assessment years. ( 2 ) THE writ petition is contested by the respondents by filing an affidavit-in-opposition. It is disclosed, inter alia, that the assessee submitted its return of income on June 30, 1973, showing a total income of Rs. 26,44,200. The assessee was refunded Rs. 7,16,639 by order under Section 141a dated November 12, 1973. The assessment was completed under Section 143 (3)/ 144b dated September 9, 1976. The total income was assessed at Rs. 33,35,870 after adjusting tax deducted at source, advance tax and refund already allowed to the assessee. The assessment order dated September 9, 1976, was revised under Section 155 (13) dated March 29, 1977, and provision for gratuity was allowed to the assessee. This led to a refund of Rs. 34,876 to the assessee. This order was again revised and a further sum of Rs. 67,314 was found refundable to the assessee on account of interest under Section 214. The assessee went on appeal and got certain reliefs. The full relief allowed to the assessee was not granted to the assessee by order under Section 250 dated January 25, 1978, since verification of earlier records was necessary. A proposal was made for action under Section 263 by the Commissioner of Income-tax, West Bengal, on the grounds that interest paid by the assessee to its head office at the United Kingdom allowed at the time of assessment, was not an allowable expenditure. The Commissioner of Income-tax, in his order under Section 263 dated September 7, 1978, enhanced the assessment and this was given effect to on September 25, 1978. The Commissioner of Income-tax, in his order under Section 263 dated September 7, 1978, enhanced the assessment and this was given effect to on September 25, 1978. The assessee requested for stay of this demand till the disposal of the appeal filed by the assessee before the Income-tax Appellate Tribunal against the order under Section 263. The assessee's petition was rejected showing reasons therefor and thereafter, a notice under Section 221 (1) and letters were issued to the assessee against which the assessee filed a writ petition. Similarly, steps were taken in respect of the assessment years 1974-75 and 1975-76. The details of the assessed amount, the reliefs available to the assessee with actual facts and figures have been fully disclosed in the affidavit-in-opposition for the three aforesaid assessment years. Other allegations of the petitioner have, however, been denied. ( 3 ) THE petitioner has also filed affidavit-in-reply reiterating the stand already taken in the main writ petition. ( 4 ) DR. D. Pal has argued at length drawing the attention of the court that the impugned orders refusing to stay and issuing notices of demand are wholly unwarranted and uncalled for and that the judicial discretion has not been exercised in the proper perspective. ( 5 ) MR. R. C. Prasad, appearing for the income-tax authorities, has taken the court through a detailed background of the case and the steps taken by the income-tax authorities at all material points of time to indicate, inter alia, that the acts are justified. ( 6 ) HAVING heard both sides at length and having considered the materials on record, a short point has arisen before this court for effective adjudication of matters in dispute. It has to be ascertained whether the impugned orders refusing to stay by assigning reasons and the issuance of notices of demand are bad in law and/or perverse in nature. It is a settled principle of law that the writ court is not certainly sitting in appeal over each and every order passed by the statutory authority. The task of the writ court to examine the decision-making process was recently found in the decision reported in State of U. P. v. Maharaja Dharmander Pvasad Singh. The writ court is averse to interfere with the acts and actions of the statutory authorities unless those are beyond jurisdiction or in excess of jurisdiction. The task of the writ court to examine the decision-making process was recently found in the decision reported in State of U. P. v. Maharaja Dharmander Pvasad Singh. The writ court is averse to interfere with the acts and actions of the statutory authorities unless those are beyond jurisdiction or in excess of jurisdiction. The writ court will certainly interfere if the impugned orders are contrary to the principles of natural justice causing in effect manifest injustice. Unless those ingredients are present, the writ court will be slow to interfere in the matter. ( 7 ) WITH great anxiety, this court has considered all materials on record and looked to the various figures of assessments made in respect of the 3 (three) assessment years as indicated above. The applications for stay have also been disposed of with reasons and those cannot be substituted by the writ court unless there is perversity in the said orders. Besides, the petitioner obtained the rule and the interim order by furnishing a bank guarantee. Upon scrutiny, this court does not find that the impugned orders and the issuance of the notices of demand are otherwise bad in law. This court is fully convinced that there is no necessity for interference by the writ court, regard being had to the background of the case and the developments which have taken place from time to time. Besides, it is not brought to the notice of the court as to what happened in the appeals and, in the meantime, more than 10 (ten) years have passed. The petitioner obtained an ad interim order by furnishing a bank guarantee. ( 8 ) FOR the foregoing reasons, the court does not find any merit in the writ petition and the rule is discharged. All interim orders are vacated. The respondents are entitled to enforce the bank guarantee in accordance with law. There will be no order as to costs.