Alternate appellate remedy bars writ challenge to Section 148 reopening notice and assessment order

A writ petition challenging a reopening notice under Section 148 of the Income-tax Act, 1961 and the consequent assessment order was not entertained because an alternate appellate remedy was available. The petitioners were relegated to the appeal mechanism, with liberty to raise all contentions before the appellate authority. The decision reflects the principle that writ jurisdiction is ordinarily not invoked where an effective statutory remedy exists, unless exceptional grounds are shown.

---

---

Issues: Whether the writ petition challenging the reopening notice under Section 148 of the Income-tax Act, 1961 and the assessment order should be entertained despite the availability of an alternate appellate remedy.

Outcome: The petition was not entertained and the petitioners were relegated to the alternate remedy of appeal, with liberty to raise all contentions before the appellate authority.

---