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    <title>2026 (4) TMI 1042 - DELHI HIGH COURT</title>
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    <description>A writ petition was held maintainable where the reassessment notice was issued beyond the prescribed limitation period and the challenge went to the root of jurisdiction. The existence of an alternate statutory remedy did not bar Article 226 review because the jurisdictional objection had been raised before the Assessing Officer and remained unanswered. The court treated the alternate-remedy rule as discretionary, not absolute, and held that it yields where proceedings are wholly without jurisdiction. The reassessment notice under section 148 and the consequential assessment order were quashed.</description>
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      <title>2026 (4) TMI 1042 - DELHI HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=789973</link>
      <description>A writ petition was held maintainable where the reassessment notice was issued beyond the prescribed limitation period and the challenge went to the root of jurisdiction. The existence of an alternate statutory remedy did not bar Article 226 review because the jurisdictional objection had been raised before the Assessing Officer and remained unanswered. The court treated the alternate-remedy rule as discretionary, not absolute, and held that it yields where proceedings are wholly without jurisdiction. The reassessment notice under section 148 and the consequential assessment order were quashed.</description>
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