Reassessment jurisdiction remains independent of return-processing appeals unless identical issues are established; preliminary writ intervention stays limited.

Reassessment initiated on information received under the statutory scheme remains distinct from return-processing and rectification proceedings, which are confined to processing adjustments. Pending appeal on such adjustments does not establish lack of jurisdiction unless the issues or amounts are shown to be identical. Objections to the adequacy or correctness of reassessment information should ordinarily be pursued through statutory reassessment and appellate remedies. Writ interference at the notice stage is confined to patent lack of jurisdiction, a legal bar, breach of natural justice, or mala fides; absent these grounds, the notice and sanction are not subject to preliminary writ intervention.

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Issues: Whether the reassessment notice issued on information received under the statutory scheme was without jurisdiction because an appeal concerning adjustments in return processing was pending, and whether the writ court should interfere at the notice stage.

Analysis: Proceedings arising from return processing and rectification are confined to adjustments made while processing the return, whereas reassessment was initiated on information received under the statutory scheme. The records did not establish that the issues or amounts in the two proceedings were identical. The information's adequacy or correctness, and objections regarding the reassessment, could be raised in the statutory reassessment and appellate process. Threshold writ interference is warranted only where the notice discloses patent want of jurisdiction, a legal bar, breach of natural justice, or mala fides; none was established.

Conclusion: The reassessment notice and sanction were not shown to be without jurisdiction, and no ground for writ interference at the preliminary stage was made out.

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