After passing of the assessment order the assessee challenged the reassessment notice and assessment order.  Dismissing the petitions the Court held that when it was asserted by the Department that the reopening of the proceedings was based on the information uploaded on Insight Portal, it was sufficient for not invoking the extraordinary jurisdiction. The ITO had specifically asserted the reopening of the assessment in the light of the information uploaded on Insight Portal and also stated to be a reason to believe that the income chargeable to tax had escaped assessment. It had also been asserted that the ITO had not received any books of account or documents or assets seized or requisitioned during the search of R. Therefore it would be necessary for the assessee to contest and challenge the assessment orders on the merits so as to substantiate his contention that the proceedings under section 147 were not justified and were without jurisdiction. The assessees did not challenge the notice issued under section 148 seeking to reopen the proceedings at that stage itself but had permitted the authorities to proceed under section 147 by responding to the notice. When in the reply to the show-cause notice the contention as regards lack of jurisdiction was not raised and was being raised after passing of the assessment orders. Writ was dismissed. (AY-2015-16)