Assessee after being supplied reasons for reopening of assessment by AO on 14.9.2018, approached Writ Court by filing Writ Petition without first raising objections before AO. This was in clear breach of procedure laid down by Supreme Court in case of GKN Driveshafts. Assessee could not without any reason or explanation, at his would choose to file Writ Petition directly before Court. In present case, assessee raised objections promptly after withdrawing petition from Court, would not in any manner dilute fact that it was on ground of assessee’s conduct that AO was left with little time to dispose of his objections and thereafter complete assessment before it become time barred. In a case where order of assessment was passed, jurisdiction of AO to pass such an order based on validity of reopening of assessment would be one part of challenge. Another part would involve challenge to assessment made by AO and would necessarily entail examination of facts on record which High Court would be loath to do as a Writ Court. Ordinarily, therefore, Court would insist that in such a situation assessee should take appellate route. Otherwise, assessee would argue jurisdictional question in High Court and if he fails, would opt to challenge order on merits before Appellate Authority, which would be most convenient. (AY. 2011-12)