Where the assessee challenged a notice under section 148 dated 12-4-2023 by filing a writ petition only on 14-1-2025, when the reassessment proceedings were getting time-barred on 31-3-2025, the High Court held that there was no justification for approaching the Court at such a belated stage and that the subsequent submissions made by the assessee were on merits and not on jurisdiction; accordingly, interim relief was refused, and the Revenue was directed to proceed with the assessment. (AY. 2016-17).