In a writ filed before the Single judge validity of issue of notice u/s 147/148 was challenged on the ground that the proceedings  should have been initiated u/s 153C of the Act and no reassessment under section 147 can be resorted. Single judge  dismissed the petition holding the initiation of proceedings were valid. On appeal the division bench of High Court set aside the order of the single judge. Court observed  that as the assessee has preferred an appeal  before the CIT (A), the assessee can raise all the issue including the validity of the proceedings initiated u/s 147/148 of the Act, by raising additional grounds.  (AY. 2016-17, 2017-18