Dismissing the petition the Court held that mere issuance of notice can never be construed as a final order. Initiation of proceedings is to be construed as information to the assessee and can never be concluded as final proceedings. The initiation cannot be interfered with by the court in writ proceedings in a routine manner. Judicial review against such initiations under the provisions of the Act, is certainly limited. The court cannot intervene in such initiations in a routine manner in the absence of any valid and acceptable legal grounds. Respondent was directed to furnish the recoded reasons from the receipt of order copy – Petitioner can file objection if any against the recorded reasons with n four weeks from the date of receipt of the reasons. (AY. 1995-96, 1996-97, 1997-98)and ( WP No. 43902 of 2006 / 29882 and 29884 of 2017 AY.1999-2000, 2001-2002 , 2002-03 ) (SJ) dt 16-10-2019 )
Seshasayee Paper and Boards Ltd. v. UOI (2019) 413 ITR 370/ 179 DTR 209 / 310 CTR 648 (Mad.)(HC),Seshasayee Paper and Boards Ltd. v .UOI (2020) 269 Taxman 120 (Mad) (HC)
S. 148 : Reassessment–Notice–Reasons for reassessment need not be given in notice-Writ is held to be not maintainable–Respondent was directed to furnish the recoded reasons from the receipt of order copy–Petitioner can file objection if any against the recorded reasons with n four weeks from the date of receipt of the reasons. [S.147, Art. 226]