The High Court held that a notice issued under section 148 is merely a show-cause notice initiating reassessment proceedings, and ordinarily no writ will lie at this preliminary stage when an effective alternative remedy exists. Challenges to such notices under article 226 should be rare since entertaining them results in unnecessary delay of pending proceedings. In the present case, the assessee contended that the notice was issued without complying with Notification No. SO 1466(E), dated March 29, 2022. However, since reassessment proceedings were still pending, the assessee had full liberty to file a reply and raise all objections before the Assessing Officer. There was no justification for the court to interfere at this stage, and the writ petition was dismissed.