Where the assessee received a show-cause notice under section 148A(b) but did not respond to the same on the assumption that the Assessing Officer lacked jurisdiction and thereafter challenged the reopening notice by filing a writ petition, the High Court held that its extraordinary jurisdiction under Article 226 could not be exercised merely because the assessee believed that it had a legal ground on which it might succeed; considering the assessee’s failure to respond to the notices, no case was made out for interdicting the reassessment proceedings. (AY. 2021-22).