Dismissing the writ petition the Court held that the assessee had not challenged the notice and had permitted the Assessing Officer to pass the assessment order. The assessee having raised the dispute on the satisfaction note as well as on the merits, it could not be said that the controversy arising in the petition was purely legal because it involved disputed questions of fact as to whether or not the satisfaction note of the Assessing Officer pertained to the incriminating material which has direct relation with the income escaped during the assessment year and for that documentary evidence was required to be appreciated. Hence the writ petition was not maintainable. Referred Godrej Sara Lee Ltd. v. Excise and Taxation Officer-cum-Assessing Authority, (2023) 109 GSTR 402 (SC); 2023 SCC OnLine SC 95.    (AY. 2016-17)