The assessee filed a writ petition challenging a reassessment order and a consequential order directing it to deposit 20 per cent of the tax demand for a stay of recovery. A statutory appeal against the reassessment order was already pending before the CIT(A). The High Court held that since a substantive appeal was pending adjudication before the competent authority under section 246A, it was not appropriate for the writ court to examine the legality of the notice for reassessment under section 148 and the consequential order passed therein. Regarding the stay order, the Court observed that it was passed after the assessee’s authorized representatives had consented to the condition of depositing 20 per cent of the demand. An order passed with such consent could not be deemed arbitrary. Accordingly, the Court declined to interfere under its writ jurisdiction. (AY. 2012-13)