Preliminary reassessment proceedings generally require statutory remedies unless jurisdiction is wholly absent or mandatory conditions are patently breached.

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....Preliminary reassessment proceedings under Sections 148A(1) and 148A(3), followed by a notice under Section 148, are investigative steps that do not determine tax liability. Challenges concerning search-based information, applicability of Section 152(3), and sanction under Section 151 should ordinarily be examined during reassessment and through statutory appellate remedies. Writ intervention at this threshold is exceptional, limited to total absence of jurisdiction or a patent breach of a mandatory pre-condition; disputes requiring appraisal of material are not ordinarily examinable under Article 226. The challenge to reassessment initiation was therefore treated as premature, with recourse left to reassessment and appellate processes.....