Writ relief in tax reassessment disputes remains limited where jurisdictional objections can be resolved under the income-tax machinery.

The Explanation to section 5(7A) of the Indian Income-tax Act, 1922 treated a transferred "case" as including all pending assessment proceedings for the relevant years, so the transfer order validly carried the petitioner's pending matters. However, where the statutory scheme and notifications vested assessment powers in a specified officer, the Income-tax Officer at Sangli had no authority to issue reassessment notices under section 34. Assessments made pursuant to those notices therefore did not bar fresh proceedings under section 148 of the Income-tax Act, 1961. The High Court declined to interfere under article 226, holding that jurisdictional questions about the place of assessment and allied matters should be resolved within the income-tax machinery.

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Issues: Whether the transfer of the pending assessment proceedings under section 5(7A) of the Indian Income-tax Act, 1922 validly carried the petitioner's pending matters to the Income-tax Officer, Bombay; whether the notices issued by the Income-tax Officer, Sangli under section 34 of the Indian Income-tax Act, 1922 were without authority and the resulting assessments could operate as a bar to fresh notices under section 148 of the Income-tax Act, 1961; and whether the High Court should interfere under article 226 of the Constitution of India.

Analysis: The Explanation to section 5(7A) made it clear that a transferred "case" included all pending proceedings in respect of the relevant years, and the order of transfer therefore covered the petitioner's pending assessment proceedings. The statutory scheme of section 5 and section 64 showed that, where a particular officer alone had been empowered by notification to perform assessment functions for specified classes of income or persons, the ordinary officer at Sangli could not validly exercise those powers. Since the Sangli officer lacked authority to issue the reassessment notices, the later assessments made pursuant to those notices could not create a legal bar to new proceedings. As to writ relief, the place of assessment and allied jurisdictional questions were matters to be decided within the income-tax machinery provided by the Act, and the court would not intervene in the circumstances shown.

Conclusion: The impugned notices were not liable to be quashed in these proceedings under article 226, and the petitioner was not entitled to relief.

Final Conclusion: The petition failed because the challenged reassessment action did not justify interference in writ jurisdiction.

Ratio Decidendi: Where the statute vests assessment functions in a specified officer and provides an internal mechanism for determining the place of assessment, writ relief will not ordinarily lie to restrain reassessment proceedings merely on the ground of alleged want of territorial or functional jurisdiction.

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