JUDGMENT VARGHESE KALLIATH, J. - This is an appeal by the petitioner in O.P. No. 4990 of 1992-R against the judgment of a learned single Judge. The learned single Judge dismissed the original petition at the first stage itself. The appellant is an assessee under the Kerala General Sales Tax Act, 1963 and the Central Sales Tax Act, 1956. The case highlighted in the original petition is that exhibits P13 to P24 are illegal and are liable to be quashed in proceedings under article 226 of the Constitution of India. He further wanted a declaration that the turnover of the 2nd respondent under the Kerala General Sales Tax Act and under the Central Sales Tax Act for 1983-84 to 1988-89 and assessed in his hands cannot be assessed in the hands of the appellant for the very same assessment years and the proceedings initiated for the said purpose are arbitrary, unauthorised and null and void. In these circumstances, he wanted this Court to issue a writ of mandamus to the first respondent to desist from proceeding with the processes taken for assessment evidenced by exhibits P13 to P24. 2. The learned single Judge found that exhibits P13 to P24 are pre-assessment notices for assessment of sales tax for the period from 1983-84 to 1988-89 and found that even if the appellant has got a good case on merits, it is not proper and appropriate for this Court to interfere with the jurisdiction exercised by an authority under the Sales Tax Act in initiating proceedings for the purpose of assessment for certain years. 3. There is no dispute that notices issued are in the process of making the assessment and to satisfy the requirement of natural justice, that the appellant should get a meaningful and pragmatic opportunity to know the mind of the assessing authority, so that he can put forward and set forth all his contentions. This is the normal and usual procedure adopted by the assessing authority. The assessing authorities have got the right and jurisdiction to make an assessment after complying with the provisions of the Sales Tax Act. To initiate proceedings for assessment is a valid exercise of power. This is the normal and usual procedure adopted by the assessing authority. The assessing authorities have got the right and jurisdiction to make an assessment after complying with the provisions of the Sales Tax Act. To initiate proceedings for assessment is a valid exercise of power. In that power, unless this Court is convinced that it is exercised by mala fides or it is exercised by an incompetent person or is so irrational and perverse that no sensible person who is in the position of the statutory authority will take such an action, this Court will not interfere with such notices which are issued for the purpose of finalising an assessment. 4. Of course, counsel for the appellant argued the case very ably and submitted that this Court is not powerless to interfere at any stage. We cannot say that we have absolutely no power to interfere with the proceedings initiated by the assessing authority, even at the first stage of issuing a notice, if we are so satisfied that there are irrefragable facts which would make it a senseless and perverse proceeding. In this case, the learned single Judge has found that the notices issued are proper notices to give the appellant the view of the assessing authority's tentative conclusion, of course subject to the final determination after hearing the objections. Even before the assessing authority the appellant has got a remedy of placing all the materials before it to escape from the liability, which he now claims before us. We are certain that the assessing authority will not proceed with the case with foreclosed mind. It will certainly consider the objections filed by the appellant to exhibits P13 to P24 notices. 5. Counsel referred us to the decisions reported in AIR 1961 SC 372 , (1961] 41 ITR 191 (SC) (Calcutta Discount Co. Ltd. v. Income-tax Officer), [1985] 59 STC 277 (SC); (1985) 3 SCC 230 (McDowell & Company Limited v. Commercial Tax Officer) and AIR 1968 SC 49 ; [1968] 67 ITR 11 (SC) (Commissioner of Income-tax v. A. Raman and Co.). All those decisions have got special features. We cannot say that there is a general dictum that this Court should interfere with the pre-assessment notices on the ground that the result of the proceedings started with the pre-assessment notices will be in favour of the assessee. All those decisions have got special features. We cannot say that there is a general dictum that this Court should interfere with the pre-assessment notices on the ground that the result of the proceedings started with the pre-assessment notices will be in favour of the assessee. We cannot arrogate ourselves to the position of the assessing authority or any appellate authority under the statute or as an authority who is deciding the question in a tax revision case. We are exercising a special jurisdiction under article 226 of the Constitution of India and in that view, it is not possible for us to interfere with the pre-assessment notices issued to the appellant. The learned single Judge considered the relevant aspects in the right perspective, though briefly. In the circumstance, we dismiss the appeal. Appeal dismissed.