Section 246(1)(a) & 246A(1)(a) of the Income Tax Act, 1961 read with article 226 of the Constitution of India — High Court was justified in refusing to entertain the writ petition filed by the assessee denying its liability to pay tax under section 115QA on the ground of alternative remedy as expression "denies his liability to be assessed" occurring in section 246(1)(a) as well as 246A (1)(a) is comprehensive enough to take within its fold every case. Where the assessee denies his liability to be assessed under the Act, hence, the appeal is maintainable against the determination of liability under section 115QA — Genpact India P. Ltd. vs. Deputy Commissioner of income tax [2019] 311 CTR (SC) 737