Writ challenge to reassessment on alleged GST and banking irregularities declined where disputed facts required verification by the Assessing Officer.

Reassessment based on alleged third-party GST and banking transactions was not quashed in writ jurisdiction because the dispute turned on contested facts, including alleged PAN misuse, fictitious GST registration, and disputed banking activity. The Court held that verification of evidence and assessment of competing factual claims fell within the Assessing Officer's competence during reassessment proceedings, and declined to decide the merits in writ proceedings. The petitioner was left to raise all factual and legal objections before the Assessing Officer.

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Issues: Whether the reassessment proceedings initiated on the basis of alleged third-party GST and banking transactions deserved to be quashed in writ jurisdiction.

Analysis: The controversy turned on factual assertions that the petitioner had not transacted with the alleged entities, that her PAN had been misused, and that the GST registration and related banking activity were fraudulent. Such matters required verification of evidence and assessment of the veracity of competing factual pleas. The Assessing Officer was held competent to examine these issues during the reassessment proceedings, and the Court declined to undertake merits adjudication in writ proceedings.

Conclusion: The petition was not entertained on merits and the petitioner was left to raise all factual and legal pleas before the Assessing Officer.

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