The assessee is a  co-operative society. In response to notices issued under section 148 of the Income-tax Act, 1961 the assessee gave a reply stating that it had inadvertently applied for permanent account number as a “firm” instead of “Association of persons”, that it was in the process of surrendering the permanent account number and thereafter would file a fresh return with the revised permanent account number as an “Association of persons” and that it was entitled to the benefit under section 80P(2)(a)(vii). Since the assessee did not file returns of income in response to the notices reassessment orders were passed. On a writ petition, the court dismissed the writ petitions filed by the assessee against the notice and the reassessment orders holding that the assessments having been made validly could not be set aside for the mere asking, the assessee being a non-filer and had not complied with the notices and questionnaires issued by the Department. On appeals the Court held that t there were no reasons to differ from the order dismissing the writ petitions. However liberty was given to the assessee to file appeals before the Commissioner (Appeals) under section 246A leaving all the issues open to be contended before him.