Writ jurisdiction cannot bypass statutory tax objections where limitation and other challenges must first be decided by the assessing officer.

A writ petition under Article 226 could not be used to challenge reassessment and scrutiny notices where the assessee's objections, including limitation, were matters the Income-tax Officer had to examine in the first instance. The court applied the principle that writ jurisdiction should not bypass the statutory process when the assessing authority is competent to decide the objections on merits. The assessee was therefore required to raise those objections before the Income-tax Officer, and the writ petition was not maintainable at that stage; the judgment entertaining it was set aside.

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Issues: Whether a writ petition under Article 226 could be entertained to quash notices issued under section 147 and section 143(2) of the Income-tax Act, 1961, when the assessee could raise all objections, including limitation, before the Income-tax Officer.

Analysis: The challenge related to the validity of the reassessment notice and the consequential notice for scrutiny, but the objection of limitation and the other grounds went to matters that the Income-tax Officer was competent to examine in the first instance. In view of the principle that writ jurisdiction should not be used to bypass the statutory process where the authority itself must decide the merits of the objections, the assessee was required to raise those objections before the Income-tax Officer.

Conclusion: The writ petition was not maintainable for deciding those objections at that stage, and the judgment allowing it was set aside.

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