High Court  dismissed the petition on the ground  that Assessing Officer was yet to frame reassessment order under section 147 and it is well settled that there is vexed distinction between jurisdictional error and error of law/fact within jurisdiction and for rectification of errors statutory remedy had been provided. On SLP   the Court held issue is  covered in UOI  v. Rajeev Bansal [2024] 301 Taxman 238 (SC), accordingly the order is disposed.  (AY. 2015-16)