Law:

Section:

JUDGMENT 1. The writ petitions in W.P. Nos. 12283 of 2013 and 5636 and 5637 of 2014 are filed challenging the assessment orders. 2. The writ petitions in W.P.Nos.33845 of 2013 and 1272, 2502, 3623, 3624, 6372 and 6373 of 2014 are filed challenging the notice issued under Section 148 or speaking order or show cause notice issued under Section 143(2) of the Act. 3. The writ petitions in W.P.Nos.27007 of 2012, 3413, 8252, 10568, 34420 of 2013 and 594 and 2772 of 2014 are filed challenging the speaking order, wherein the original assessment orders have been passed under Section 143(1)/under Section 144 and the reassessment notice has been issued within four or six years. 4. The writ petitions in W.P.Nos.201 to 203, 1924, 1925, 3005, 7137, 7138, 7643, 8171, 12357, 24770, 31937, 31938 of 2013 and 1941, 2771, 3275 to 3277 and 8495 of 2014 have been filed challenging the speaking order wherein the notice for reassessment has been issued within four years from the relevant assessment year wherein original orders have been passed under Section 143(3)/under Section 147. 5. The writ petitions in W.P.Nos.19871, 27609, 29467, 30610, 34985, 34986 of 2012, 1441, 6111, 6768, 7044, 7275, 12358, 12359, 33844 of 2013 and 3847 and 5744 of 2014 are filed challenging the speaking order wherein the notice for reassessment has been issued after four years and within six years from the relevant assessment year wherein orders have been passed under Section 143(3)/under Section 147. 6. The Writ Appeals in W.A.Nos.347 to 349 of 2014 are filed by the Revenue challenging the interim orders granted in the writ petitions. 7. Though we heard the arguments at length at the bar, both on the issues of law and facts, we deem it fit to consider the fundamental and primary issues governing the case, which, if decided, would make the other issues as unnecessary. The core issues for consideration before this Court are: ''(1) Whether an order passed by the assessing officer on the objections of an assessee can be assailed before the Court under Article 226 of the Constitution of India? (2) Whether an assessment/re-assessment order passed under Section 147 read with 143(3) of the Income-tax Act, 1961 is…

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