Where reassessment notices under S. 148 were issued by income-tax officials at Kolkata and the entire record, material and assessing jurisdiction were also situated in Kolkata, the Bombay High Court held that the mere fact that the assessee had its registered office in Mumbai was not sufficient to confer writ jurisdiction. Even if a minuscule part of the cause of action could be said to have arisen in Mumbai, that by itself could not compel the Court to exercise discretionary jurisdiction under Article 226. The jurisdiction depends on the location of the authority passing the impugned order/notice, and the residence or location of the affected person is irrelevant. Applying the principle of forum conveniens, the Court held that the interest of justice would be served by relegating the assessee to avail remedies before the appropriate forum at Kolkata. Reliance was placed on Lt. Col. Khajoor Singh v. UOI  AIR 1961 SC 532, PCIT v. ABC Papers Ltd. and Sterling Agro Industries Ltd (2022) 328 CTR 129/ (2022) 9 SCC 1.