Dismissing the petition the Court held that the progress made on account of certain facts, events and procedures, which were otherwise contemplated under the provisions of the Act, could not be construed as without jurisdiction nor to be termed as legal malice. No mala fides or lack of jurisdiction was identifiable nor established. The section 147 proceedings had been initiated for a particular assessment year and only after invoking section 153C, could the Assessing Officer prepare the “satisfaction note” and reopen proceedings for five assessment years. The assessee had to defend his case before the competent authority in the manner known to law. Such an adjudication with reference to the transactions, seizure and impounded materials could not be undertaken by the High Court under article 226 of the Constitution of India. The notice under section 153C was valid. (AY. 2014-15, 2015-16)