Dismissing the writ petition the Court held that  the assessee could have filed an appeal from the assessment order on or before May 28, 2022, even without a delay condonation application. The writ petition itself had been filed only on November 2, 2022 almost five months after the time granted by the Supreme Court had expired. There was also no explanation as to why the assessee did not approach the appellate authority within the time provided by the Supreme Court. Hence the orders of assessment and penalty need not be interfered with in writ jurisdiction. The assessee was relegated to statutory remedy of appeals before the Commissioner (Appeals) under section 246A and the Tribunal under section 253.