On writ against the issue of reassessment proceedings  the single judge proceeded to consider the effect of section 153C and observed that nowhere in section 147, the provisions of section 153C stood excluded. The assessee was permitted to file an appeal before the first appellate authority. On appeal allowing the appeal, the division bench held that the   contentions raised by the assessee with regard to the validity of the reopening proceedings had not been decided. In any event, the assessee had filed appeals before the first appellate authority within the period of limitation. Therefore, the assessee was relegated to pursue the appellate remedy. The observations rendered by the court might cause prejudice to the assessee or to the Department were vacated, as they would amount to putting fetters on the exercise of the powers of the appellate authority. Therefore, all issues were left open and the assessee was at liberty to contend all factual and legal issues before the first appellate authority. The order passed in the writ petitions was set aside. The assessee was also granted liberty to raise additional grounds if a need arose. (AY. 2016-17, 2017-18)