4.The order of assessment would reveal that certain materials, informations, based on the reopening of assessment was considered and order was passed. Thus, finding in the assessment order impugned require an adjudication with reference to the original records available. Such an adjudication cannot be done by the High Court in a writ proceedings under Article 226 of the Constitution of India. Certain intricacies and expertise in the matter of accountancy are to be considered by the appellate authorities and it may not be appropriate on the part of the High Court at this juncture to venture into the disputed transactions as well as the other materials available on record. Thus, the final fact finding by the appellate authority would be of assistance for the purpose of exercise of the power of judicial review by the High Court under Article 226 of the Constitution of India. Thus, exhausting the appellate remedy is of paramount importance and at no circumstances, be undermined. In the event of adjudication of the facts and circumstances, which all are disputed in a writ proceedings, the aggrieved persons are deprived of an opportunity of getting redressal through the appeals which is contemplated under the statute. The appeals are provided with a legislative intention to provide an effective adjudication by the higher authority
