The single judge relegated the assessee to the statutory remedy of appeal under the Act. On appeal  dismissing the appeal the Court held that   whether appreciation of the documents was done or not and whether there was sufficient opportunity granted to the assessee or not were all issues which could be contended before the first appellate authority in appeal under section 246A of the Act and there was no valid reason for the assessee to bypass the statutory appeal remedy. The liberty granted to the assessee by the single judge in his order was sustained. (AY. 2007-08)