Article 226 restraint on show-cause notices: jurisdictional objections should be raised before the assessing authority, with statutory remedies preserved.

High Court writ interference is ordinarily unavailable against a show-cause notice or during pending assessment proceedings under Article 226. The assessing authority should first consider any preliminary objection that it lacks jurisdiction and decide that issue in the course of the assessment. The affected party may raise all jurisdictional and other pleas before the authority, and if dissatisfied with the eventual order, pursue the statutory remedies available thereafter. Interlocutory intervention at the notice stage was therefore declined, and the writ petition was not entertained on merits.

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Outcome: Writ petition disposed of without interference at the stage of show cause notice, leaving the petitioner to raise all pleas before the assessing authority and pursue statutory remedies thereafter.

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