( 1 ) GENERAL OBSERVATIONS. The immediate context of the consideration of this writ petition is the issue of notice to the petitioner assessee by its Income-tax Officer under section 148 (1) of the Income-tax Act, 1961 (the Act), because he had "reason to believe" within the meaning of section 147 of the said Act that the income of the assessee had escaped assessment. The petitioner challenges the validity of this notice on the ground that no material existed on which the Income-tax Officer could have reason to believe that its income had escaped assessment and consequently the notice was issued without jurisdiction. The Income-tax authorities have raised the preliminary objection that the writ petition is not maintainable because appeals would lie under section 246 against the order of reassessment made under section 147 and as this remedy is provided for by the Income-tax Act the present writ petition for the redress of any injury or alleged injury suffered by the petitioner by the issue of the notice, which may subsequently lead to orders of reassessment, cannot be entertained in view of the existing clause (3) of Article 226. But clause (3) of Article 226 of