Single judge dismissing the writ petition against the reassessment notice on the ground that the disputed facts cannot be adjudicated in writ proceedings. As regards the limitation the Court held that in the absence of any order communicated the Assessing Officer, it was not possible for the department to act in a particular manner. Order passed based on the final assessment order was within limitation period and not barred by limitation.  On appeal division bench affirmed the order of single judge.  The Court also held that the assessee has to necessarily avail the appellate remedy as against the order of reassessment and agitate all issues on merits.  As regards  the limitation  the Court held that the assessee having enjoyed the benefit of the interim order passed by the Supreme Court on 8^th December 2016, restoring the position, which stood on 8^th June, 2014  is not entitle to maintain a challenge to the reopening / reassessment on the ground of limitation. The contentions with regard to the limitation which have been rejected. (AY. 2007-08)