Held, that the Assessing Officer could not assume the jurisdiction to reopen the assessment for the assessment year 2016-2017 to again reappreciate the same facts which he had considered during the course of the assessment year 2015-2016 to disallow the exemption under section 54F of the Income-tax Act, 1961 on the ground that three years from the date of deposit in the Capital Gains Deposit Scheme would be over on January 30, 2016 which would fall in the previous year relevant to the assessment year 2016-2017. The notice dated May 30, 2019, issued under section 148 of the Act was liable to be quashed. The Supreme Court in the case of Calcutta Discount Co. Ltd. v. ITO, (1961) 41 ITR 191 (SC); 1960 SCC OnLine SC 10 held that the High Courts have power to issue a writ in a fit case, prohibiting an executive authority from acting without jurisdiction, and an existence of alternative remedy as appeals and reference to the High Court would not be a sufficient reason for refusing quick relief by a writ or order prohibiting an authority acting without jurisdiction from continuing such action.(AY. 2016-17)