Sec. 147 of the Income-tax Act, 1961 - Reassessment - When the High Court was moved in the writ proceedings for challenging the reopening of the assessment for Assessment Year 2013-14, the Court observed that the objections to the reopening of the assessment are the same as those before the CIT (A) for A.Y 2015-16. Observing that any expression of opinion on the reopening of the assessment will affect the pending appeal before the CIT (A), the High Court disposed of the writ petition, keeping open the challenge to be raised in appropriate legal proceedings. High Court justifiably held that it would not be appropriate to exercise jurisdiction under article 226 when the same issue is already pending before the CIT (A) for Assessment Year 2015-16. - SHRI SAIBABA SANSTHAN TRUST V/s UOI - [2020] 270 TAXMAN 197 (SC)