In writ proceedings challenging an order passed under section 148A(d) and consequential notice under section 148, the High Court held that at the pre-notice stage, the scope of judicial review is confined only to examining the existence of information suggesting escapement of income. Issues such as sufficiency or correctness of material, or merits of the proposed reassessment, cannot be adjudicated under article 226. A show-cause notice under section 148A(b) must contain precise and concise information enabling the assessee to understand the Assessing Officer’s mind and to respond effectively. The assessee had denied the allegation of accommodation entries and sought the underlying material; however, the Assessing Officer, after considering the reply and available information, recorded satisfaction that it was a fit case for issuance of notice under section 148. The Court held that (i) observations in an order under section 148A(d) do not prejudice the assessee or the Department since the reassessment will proceed independently under section 147; and (ii) the assessee failed to show non-application of mind or that the findings were contrary to record. At this intermediary stage, interference under articles 226 or 227 was unwarranted. Writ petition dismissed. (AY 2017-18)