Dismissing the petition the Court held that there was no violation of the principles of natural justice, and there was no reason to interfere with the assessment order. The ITO had not acted without jurisdiction. Whether such jurisdiction had been exercised incorrectly or there was an error in such exercise was a different issue to be tested under the statutory appeal available under the Act. The ITO had dealt with the contentions raised by the assessee and had arrived at a particular finding and interfering with it at this stage might not be the correct course of action. The assessee was relegated to the remedy of statutory appeal under section 246A before the Commissioner (Appeals). Relied on UOI v. Guwahati Carbon Ltd. [2012] 278 ELT 26 (SC) and CIT v. Chhabil Dass Agarwal [2013] 357 ITR 357 (SC) , distinguished  ACIT v. Balmiki Prasad Singh [2018] 408 ITR (St.) 19 (SC) .  Court observed that  the extraordinary jurisdiction under article 226 of the Constitution of India is required to be sparingly used only when the court finds that the action of the State is without jurisdiction, in violation of principles of natural justice or the order passed is palpably illegal. However the provisional attachment u/s 281B was quashed .   ( AY. 2017-18)