Allowing the petition the Court held that the assessee had approached the High Court upon notice being issued under section 148 of the Act. Such notice was challenged on multiple grounds and the court had granted an interim stay at the time of admission. In spite of the order of stay, the respondents proceeded to issue the assessment order on the following day. In the overall facts and circumstances, this was an appropriate case to exercise jurisdiction under article 226.  Court also held that  the reason cited for reopening the assessment for the assessment year 2013-14 was the deletion of Rs. 86,93,77,010 under the head “land” without offering capital gains for assessment. The assessment order clearly disclosed that no additions were being made on this account since there were no capital gains. The assessee had approached the court soon thereafter and the court had granted interim stay of further proceedings on March 30, 2022. The assessment order dated March 31, 2022 came to be issued in these facts and circumstances with additions in an aggregate sum of Rs.1,49,93,830 under various heads. Significantly, no addition was made regarding the transaction that triggered the reopening of assessment. Hence the notice under section 148 and the assessment order issued on March 31, 2022 were not valid.   (AY.2013-14)