Dismissing the petition the Court held that there had been no procedural irregularity. Notices were issued under section 148 of the Act, pursuant to which, return was filed by the assessee for the relevant AYs, and thereafter, reasons were sought for, the reasons were given by the Revenue, and those reasons had been objected. The assessee being the Indian subsidiary company of a foreign company had earned income, according to the Revenue, and the income had not been brought or routed through the profit and loss account, i. e., the profit and loss account of the relevant financial year and this had been unearthed subsequently only by the Revenue and prima facie, according to the Revenue, there had been a net freight of Rs. 29,50,53,532 collected through the Indian subsidiary company after allowing the expenditure, which according to the Revenue, escaped assessment. These minute details could not be gone into by the court by exercising its extraordinary jurisdiction under article 226 of the Constitution. The notice was valid. (AY. 2013-14, 2015-16)