Where the assessee challenged the reassessment notice issued pursuant to proceedings under section 148A contending that the information relied upon in the notice was erroneous and duplicated, the Court held that the petition contained no prayer challenging the constitutional validity of section 135A and, in absence of proper pleadings and reliefs, such constitutional issue could not be examined. The dispute raised by the assessee involved adjudication of factual aspects regarding correctness of statements contained in the notice, which required detailed examination by the Assessing Officer and could not be undertaken in writ jurisdiction under Article 226. Since the reassessment scheme itself contemplated full opportunity to the assessee during proceedings and no jurisdictional error or lack of authority was demonstrated in issuance of the notice, interference at the notice stage was unwarranted. Accordingly, the writ petition seeking quashing of reassessment proceedings was dismissed. (AY. 2020–21).