Reassessment notice dealing with question of facts, can’t be challenged before HC

Tamilnad Mercantile Bank Ltd. Vs ACIT (Madras High Court)

Facts- The writ petitioner filed ROI qua said AY on 25.09.2014 u/s. 139(1) of IT Act; that the original assessment order (based on such return) was made by the AO vide an order dated 22.12.2016; that thereafter the impugned notice under Section 148 of IT Act came to be issued; that impugned notice reverted the matter to the earlier part of Chapter XIV of IT Act and therefore a notice dated 23.11.2021 being a notice under Section 142(1) of IT Act with

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