Palaniammal Palaniappan v. ITO (2021) 434 ITR 668 (Mad.)(HC)

S. 148 : Reassessment-Notice-Proper procedure to be adopted-Writ against the notice was dismissed. [S.147, Art. 226]

Dismissing the petition the Court held that a writ petition against a notice under section 148 was not to be entertained in a routine manner.  The notice could be challenged if the issuing authority had no jurisdiction or if it was issued beyond the period of limitation. If the ground regarding limitation existed, the assessee could raise such issue before the competent authority and not before the court. (AY. 2011-12)