Dismissing the petition the Court held that the Commissioner had merely issued a notice for taking the of assessment in revision , it was open to both sides to raise all contentions before the Commissioner and there after take the matter further as may be found necessary. At the stage of dealing only with the notice of the Commissioner taking the order of assessment in revision , the High Court would not interfere other than in a case where the Commissioner lacks jurisdiction . Therefore , the writ petition was not maintainable .( AY. 2011-12)