Writ challenge to reassessment declined for disputed facts and availability of statutory appeal under income-tax law.

Writ jurisdiction under Article 226 was declined where the challenge to reassessment turned on disputed factual assertions about an allegedly unauthorised bank account and related transactions. The court treated those matters as unsuitable for writ determination and noted that the reassessment process had already been preceded by notice under Section 148A(b), an order under Section 148A(d), and notice under Section 148, with a statutory appeal available under the Income-tax Act, 1961. Interference was therefore refused and the petitioner was left to pursue the statutory remedy.

---

---

Issues: Whether the writ petition challenging the reassessment order was maintainable in view of disputed questions of fact and the availability of a statutory appeal under the Income-tax Act, 1961.

Analysis: The challenge rested on the claim that a bank account had been opened without the petitioner's knowledge and that the transactions in that account led to the reassessment. The Court treated these assertions as disputed factual issues not suitable for determination in writ proceedings under Article 226 of the Constitution of India. It also noted that the reassessment had been preceded by notice under Section 148A(b) of the Income-tax Act, 1961, an order under Section 148A(d) of the Income-tax Act, 1961, and notice under Section 148 of the Income-tax Act, 1961, and that a statutory appeal was available.

Conclusion: Interference in writ jurisdiction was declined and the writ petition was dismissed, leaving the petitioner to work out the statutory remedy.

---