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2023 (4) TMI 1292 - CALCUTTA HIGH COURTReopening of assessment u/s 147 - validity of order u/s 148A(d) - HELD THAT:- This is not a case where the impugned order has been passed in violation of principle of natural justice or the impugned order is without jurisdiction or there is any procedural irregularity in passing the order though it may be that the petitioner is not satisfied with the reasoning given in the aforesaid order but that can’t be a ground for involving constitutional jurisdiction of this court under Article 226 of the constitution of India. Furthermore in this case, final assessment order u/s 147 of the Act has already been passed according to the petitioner which is an appellable order under the statute and which is not the subject matter of challenge in this writ petition. In view of the discussion made above, this writ petition is dismissed. This Court has not gone into the merits of the final assessment order passed u/s 147 of the Act since it is not the subject matter of this writ petition.
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