The petitioner filed his return of income for AY 2015-16, which was  accepted under Section 143(3) of the Act. Subsequently, based on audit objections, the Assessing Officer issued a notice under Section 148 for reassessment, citing incorrect deduction under Section 54F and non-disclosure of rental income under Section 23. The petitioner objected  that the reassessment was based on a change of opinion and at the behest of the audit party. However, the reassessment order was passed, making additions to income from house property and disallowing part of the deduction under Section 54F. The petitioner challenged the reassessment order through a writ petition, contending that no sufficient opportunity of hearing was provided and raising objections under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act (TOLA). The High Court dismissed the writ petition, holding that the petitioner had an alternate remedy of appeal under Chapter XX of the Income-tax Act. The court noted that the objections regarding TOLA and jurisdiction under Section 147 were not raised during the original reassessment proceedings. It further held that disputed facts could not be adjudicated in writ jurisdiction and directed the petitioner to file an appeal within four weeks, extending the ad-interim relief for the same period. The court also observed  that it had not expressed any opinion on the merits and left all issues open for adjudication by the appellate authority. (WP No. 9833 of 2022, dt. 05-02-2025)(AY. 2015 -16 )