The assessee was issued a notice under section 148 of the Act on a writ petition contending that the procedure adopted in reopening the assessment was illegal.  Dismissing the petition the Court held the reassessment proceedings under section 147 had started with the issuance of the notice under section 148 and the assessee had taken part in the proceedings. The Department had not taken a final decision with regard to the reassessment proceedings. Therefore, the writ petition was premature and not maintainable. (AY.2017-18)