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HC dismissed writ petition challenging reopening of assessment under section 147, where petitioner failed to respond to show-cause notices issued under section 148A regarding undisclosed materials and transactions. Court held that since petitioner received departmental notice but chose not to contest before Competent Authority and final assessment order was already passed, it was inappropriate to invoke writ jurisdiction under Article 226. HC determined that grounds raised could be addressed before Appellate Authority in accordance with law. Decision aligned with previous ruling involving same petitioner for different assessment year, where statutory remedies were deemed adequate. Writ petition dismissed with direction to pursue available appellate remedies under the Act.
HC dismissed writ petition challenging reopening of assessment under section 147, where petitioner failed to respond to show-cause notices issued under section 148A regarding undisclosed materials and transactions. Court held that since petitioner received departmental notice but chose not to contest before Competent Authority and final assessment order was already passed, it was inappropriate to invoke writ jurisdiction under Article 226. HC determined that grounds raised could be addressed before Appellate Authority in accordance with law. Decision aligned with previous ruling involving same petitioner for different assessment year, where statutory remedies were deemed adequate. Writ petition dismissed with direction to pursue available appellate remedies under the Act.
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