https://www.taxtmi.com/caselaws?id=49324 A writ court may examine a challenge to a reopening notice where the petition specifically alleges absence of jurisdictional facts or a colourable exercise of power. If the pleadings, if proved, would show that the authority lacked jurisdiction or was using reassessment as a cloak for a fishing inquiry or review of an earlier assessment, the authority should ordinarily be called upon to answer before the petition is rejected at the threshold. Summary dismissal in limine remains permissible only where the petition is plainly unsustainable or other discretionary grounds, such as delay, acquiescence, alternative remedy, or misrepresentation, are apparent. In disputed jurisdictional matters, the High Court should not refuse relief without enquiry. en-us Thu, 08 Apr 1965 00:00:00 +0530 Wed, 20 Aug 2014 09:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49324 A writ court may examine a challenge to a reopening notice where the petition specifically alleges absence of jurisdictional facts or a colourable exercise of power. If the pleadings, if proved, would show that the authority lacked jurisdiction or was using reassessment as a cloak for a fishing inquiry or review of an earlier assessment, the authority should ordinarily be called upon to answer before the petition is rejected at the threshold. Summary dismissal in limine remains permissible only where the petition is plainly unsustainable or other discretionary grounds, such as delay, acquiescence, alternative remedy, or misrepresentation, are apparent. In disputed jurisdictional matters, the High Court should not refuse relief without enquiry. Case-Laws Income Tax Thu, 08 Apr 1965 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49324