Section 147 & 148 of the Income Tax Act, 1961 read with article 226 of the Constitution of India - The discretionary jurisdiction under article 226 is not absolute but has to be exercised in the given facts of a case and in accordance with law. Writ petition challenging notice should be filed before conclusion of reassessment proceedings — Doosan Bobcat India P. Ltd. vs. Deputy Commissioner of income tax [2020] 420 ITR 84 (Madras).