High Court Appeal Challenged: Alternate Remedy Exists for Reopening Assessments u/s 147, Directs to Appellate Authority.

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....Maintainability of appeal in High Court - alternate remedy - Reopening of assessment u/s 147 - the opportunity of an aggrieved person to adjudicate the legal grounds must be allowed to be provided before the appellate authority or before the Tribunal, as the case may be. The High Court cannot adjudicate the disputed facts in a writ proceedings for the purpose of considering certain legal grounds. When the appellate authority is competent to adjudicate such legal grounds, the opportunity and the benefit of an appeal cannot be denied to an aggrieved person. - HC....