Held, dismissing the writ appeal, that the challenge to initiation of proceedings under section 148 of the Income-tax Act, 1961, was raised only on the ground of non-issuance of sanction order under section 151 of the Act by the competent authority. The present was not a case warranting exercise of powers under article 226 of the Constitution of India, having regard to the fact that the assessee had adequate alternate remedy by way of appeal. The notice of reassessment could not be quashed.