Reassessment notice challenge rejected as premature; assessment proceedings to continue under earlier remand directions.

A writ challenge to a reassessment notice was held not to warrant interference where the notice was clear in context and the proceedings were a continuation of an earlier remand. The Court noted that the petitioner had already responded to the notice and sought time, and that approaching writ jurisdiction at that stage would unnecessarily stall the assessment process. The assessment was to proceed in accordance with the earlier directions and the applicable provisions, with a further opportunity to file a reply and completion directed within the stipulated time.

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Issues: Whether the challenge to the notice issued in the reassessment proceedings for the relevant assessment year was maintainable and whether interference under writ jurisdiction was warranted.

Analysis: The notice was found to be clear in context and content, despite reference to the earlier assessment order that had already been set aside. The petitioner had already responded to the notice and sought time, but then approached the Court in a manner that unnecessarily stalled the assessment proceedings. The Court noted that the proceedings were in continuation of the earlier remand and were to be completed in accordance with the earlier directions and the applicable provisions governing the assessment.

Conclusion: The writ challenge was rejected and the assessment proceedings were permitted to continue, with a direction to complete the assessment within the stipulated time and to grant a further opportunity to submit reply.

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