The assessee challenged a reassessment order via a writ petition, contending that the sanction for reopening the assessment, obtained under section 151, was invalid in light of binding High Court precedents. However, prior to filing the writ petition, the assessee had already initiated statutory remedies by filing an appeal before the CIT(A) and a revision application under section 264 against the very same order.

The High Court held that a writ petition should not be entertained when an assessee has already invoked alternative statutory remedies. It reasoned that the appellate and revisional authorities are bound to consider and apply the law laid down by the jurisdictional High Court, including the precedents cited by the assessee. Accordingly, the Court directed the assessee to pursue the pending appeal and revision proceedings. As an interim measure, the Court stayed the operation of the impugned assessment order until the disposal of these proceedings.