ORDER : Ananda Sen, J. 1. By filing this writ petition, petitioner has prayed to quash the notice dated 14.03.2018 issued under Section 148 of the Income Tax Act, 1961 for the A.Y. 2011-12. He also prayed to quash the re-assessment proceeding consequent to the said notice on the ground that the same is malafide. Further a prayer has been made to quash the notice dated 23.08.2018 issued under Section 142(1) of the Income Tax Act, 1961, on the ground that the same was issued in a mechanical manner without meeting the objection put forth by the petitioner. He has further prayed to quash the notice dated 12.02.2018 issued by the Valuation Officer. Prayer has also been made to quash the order dated 22.11.2018 including its corrigendum dated 28.11.2018, which according to the petitioner has been passed without considering the objection raised by the petitioner. 2. We have heard learned counsel for the petitioner and learned counsel for the respondent (Revenue Department) at length. 3. Challenging the notice dated 21st August, 2018, learned counsel for the petitioner submits that the assessment of escaped income of Rs.7,00,000/- and Rs.1,08,00,000/- is bad and nonest. He argues that in the enquiry report, there is no mention about Mangal Metals, which, according to the Revenue Department is a shell company. In absence of any reference or any investigation with regard to Mangal Metals, the transaction with Mangal Metals cannot be said to be fictitious and said Mangal Metal cannot be termed as a shell company. He also argues that the Revenue Department has played fraud with this Court and in the earlier counter affidavits, the enquiry report, which was annexed does not whisper about Mangal Metals, whereas in the Supplementary Counter Affidavit filed on 16.10.2023, the Revenue Department has annexed a report, in which there is some reference of Mangal Metals. He submits that the instant case was pending since long, i.e., from 2018, but only in 2023, report was filed suggesting that Mangal Metals is a shell company, but in the earlier reports, filed from time to time, there is no whisper about the said company. As per the counsel for the petitioner, report, filed through Supplementary Counter Affidavit on 16.10.2023, is nothing but to cover up the laches. As per the counsel for the petitioner, report, filed through Supplementary Counter Affidavit on 16.10.2023, is nothing but to cover up the laches. Further, he submits that there is reference of another company named as West Overseas Trade Link (P) Ltd., but the income derived from the said company was not of the assessment year 2010-11, but of a period, which is prior to that. The said income cannot be said to have been generated in the previous year. When the income was not generated in the previous year, the same cannot be a subject matter of escaped income. It is also submitted that on a non-existent provision of law, notices were issued to the petitioner. Petitioner lastly submits that there were no “reasons to believe” that there is an escaped income, thus, in absence of any reasons to believe, notices issued are absolutely bad and needs to be set aside. 4. Learned counsel appearing on behalf of the respondents (Revenue Department) submitted that the enquiry report clearly suggests that both Mangal Metals and M/s West Overseas Trade Link (P) Ltd. are shell companies as on physical verification they did not find any company existing in the premises. There was income shown from the said companies and these two companies, namely, Mangal Metals and West Overseas Trade Link (P) Ltd. are shell companies, thus, there was sufficient reasons to believe that there is escaped income in the instant case, which necessitated issuance of the aforesaid notice. 5. The petitioner was proceeded against for the assessment year 2011-12. The Department had reasons to believe that the income of Rs.1,15,00,000/-(Rs.7,00,000/-+ Rs.1,08,00,000/-) is escaped income for which notices were issued to the petitioner. These notices are being challenged by filing this writ of certiorari. No doubt, if a notice is without jurisdiction or is based on a non-existent ground or is in utter violation of the provisions of law, the same can be challenged. 6. The Hon’ble Supreme Court in the case of The Income Tax Officer, I Ward, District VI, Calcutta & Others versus Lakhmani Mewal Das reported in (1976) 3 SCC 757 at paragraph 8 thereof has held as under: - “8. 6. The Hon’ble Supreme Court in the case of The Income Tax Officer, I Ward, District VI, Calcutta & Others versus Lakhmani Mewal Das reported in (1976) 3 SCC 757 at paragraph 8 thereof has held as under: - “8. The grounds or reasons which lead to formation of the belief contemplated by section 147(a) of the Act must have a material bearing on the question of escapement of income of the assessee from assessment because of his failure or omission to disclose fully and truly all material facts. Once there exist reasonable grounds for the income-tax Officer to form the above belief, that would be sufficient to clothe him with jurisdiction to issue notice. Whether the grounds are adequate or not is not a matter for the court to investigate. The sufficiency of grounds which induce the Income-tax Officer to act is, therefore, not a justiciable issue. It is, of course, open to the assessee to contend that the Income-tax Officer did not hold the belief that there had been such non-disclosure. The existence of the belief can be challenged by the assessee but not the sufficiency of the reasons for the belief. The expression “reason to believe” does not mean a purely subjective satisfaction on the part of the Income Tax Officer. The reason must be held in good faith. It cannot be merely a pretence. It is open to the court to examine whether the reasons for the formation of the belief have a rational connection with or a relevant bearing on the formation of the belief and are not extraneous or irrelevant for the purpose of the section. To this limited extent, the action of the Income-tax Officer in starting proceedings in respect of income escaping assessment is open to challenge in a court of law see observations of this Court in the cases of Calcutta Discount Co. Ltd. v. Income Tax Officer and S. Narayanappa v. CIT while dealing with corresponding provisions of the Indian Income Tax Act, 1922.” 7. Further the writ of certiorari is not an appellate jurisdiction. In the case of Pratap Mehta Vs. Sunil Gupta & Others, reported in (2019) 13 SCC 558 , the Hon'ble Supreme Court at pargraph 35 thereof has held that a writ of certiorari can be issued for correcting errors of jurisdiction committed by inferior courts or tribunals. Further the writ of certiorari is not an appellate jurisdiction. In the case of Pratap Mehta Vs. Sunil Gupta & Others, reported in (2019) 13 SCC 558 , the Hon'ble Supreme Court at pargraph 35 thereof has held that a writ of certiorari can be issued for correcting errors of jurisdiction committed by inferior courts or tribunals. It was further held that jurisdiction of the High Court under Article 226 to issue a writ of certiorari is a supervisory jurisdiction and the High Court exercising it is not entitled to act as an appellate court. 8. In the case of General Manager, Electrical Rengali Hydro Electric Project & Others Versus Giridhari Sahu & Others, reported in (2019) 10 SCC 695 , the Hon'ble Supreme Court at paragraph 28 thereof has held that the jurisdiction to issue writ of certiorari is supervisory and not appellate. The Court considering a writ application of certiorari will not don the cap of an appellate court. It will not re-appreciate evidence. The writ of certiorari is intended to correct jurisdictional excesses. The Hon'ble Supreme Court further held that once a decision is rendered by a body amenable to certiorari jurisdiction, certiorari could be issued when a jurisdictional error is clearly established. The jurisdictional error may be from failure to observe the limits of its jurisdiction. It may arise from the procedure adopted by the body after validly assuming jurisdiction. It may act in violation of principles of natural justice. The body whose decision which comes under attack may decide a collateral fact which is also a jurisdictional fact and assume jurisdiction. Such a finding of fact is not immune from being interfered with by a writ of certiorari. 9. In the instant case, we find that the ground for reopening the assessment is that the respondents had reasons to believe that both the companies are shell companies and the petitioner did not disclose the income. The enquiry report is on record. The said enquiry report is dated 07.02.2018, signed by two Inspectors of Income Tax Department. 9. In the instant case, we find that the ground for reopening the assessment is that the respondents had reasons to believe that both the companies are shell companies and the petitioner did not disclose the income. The enquiry report is on record. The said enquiry report is dated 07.02.2018, signed by two Inspectors of Income Tax Department. The said report deals with M/s. West Overseas Trade Link (P) Ltd. From the enquiry report, it is clear that there is no office in the name and style of West Overseas Trade Line (P) Ltd. Physical verification was made in the building, which was recorded as registered office in the books, but the office was found to be non-existent. It is necessary to quote the enquiry report, which reads as under : Inquiry Report As directed, I had been duly authorized along with another Inspector of this range office, i.e.; Sri Satish Kumar Singh, to conduct an open inquiry regarding the identity, Creditworthiness, and genuineness of the companies in the case of M/s Amit Realty Pvt. Ltd. (PAN- AAGCA3858B), in connection with the Survey operation u/s 133A conducted in the business premises at 4th Floor, Bokaro Mall, Sector-3C, Bokaro Steel City of the aforesaid assessee on 18/01/2018. The inquiry was connected with the investments by the companies/ Parties listed in the Annexure-“A” n the form of Share Capital/ Share Premium/Loan provided to the M/s Amit Realty Pvt. Ltd., Bokaro. In connection to this, we visited Kolkata on 25th January 2018. The followings facts were observed while doing the inquiry with respect to the companies listed in the Annexure-“A”:- 1. M/s West Overseas Trade Link Pvt. Ltd.:- The registered address of the Company was 5, Sukhlal Johri Lane, 1st Floor, Kolkata-700007. On going there we found that there were 3 shops along with one office named as M/s Satyam Enterprises and that also all closed ones. In the adjacent side of these shops, one residential flat was also there. One lady of that flat told us that all the closed shops are of garments (saree) only and there is no such office in the name and style of the M/s West Overseas Trade Link Pvt. Ltd. That lady further stated that there is no such office on the other floor also. One lady of that flat told us that all the closed shops are of garments (saree) only and there is no such office in the name and style of the M/s West Overseas Trade Link Pvt. Ltd. That lady further stated that there is no such office on the other floor also. The address of this company mentioned at the website maintaining this database WWW.Zauba.Com was 205, Rabindra Sarani, 3rd floor, Room No.103, Kolkata-700007. After getting there, we found that, the entire building was of old age used completely for commercial purpose. At the 3rd floor, there were various rooms allotted for the office of different companies but no such name plate was there that belongs to the concerned company. One of the office bearer of the company named as “Fighter International” denied the existence of any such company at that floor.” This is for your kind information and necessary direction, if any. (Satish Kumar Singh) Inspector of Income Tax Ward-3(4), Bokaro (Rupesh Kumar) Inspector of Income Tax Ward-3(2), Bokaro 10. Similarly, in the Supplementary Counter Affidavit dated 16.10.2023, an enquiry report was annexed, which relates to M/s Mangal Metals Pvt. Ltd. From perusal of the report, prima facie it appears that the company is also non-existent. It is necessary to quote the relevant portion of the said report, which reads as under : Inquiry Report As directed, I had been duly authorized along with another Inspector of this range office, i.e.; Sri Rajeev Kumar, to conduct an open inquiry regarding the identity, Creditworthiness, and genuineness of the companies in the case of M/s Amit Realty Pvt. Ltd. (PAN- AAGCA3858B), in connection with the Survey Operation u/s 133A conducted in the business premises at 4th Floor, Bokaro Mall, Sector-3C, Bokaro Steel City of the aforesaid assessee on 18/01/2018. The inquiry was connected with the investments by the companies/ Parties listed in the Annexure-“A” n the form of Share Capital/ Share Premium/Loan provided to the M/s Amit Realty Pvt. Ltd. Bokaro. In connection to this, we visited Kolkata on 01st and 2nd February 2018. The followings facts were observed while doing the inquiry with respect to the companies listed in the Annexure-“A”:- 1. … 7. M/s Mangal Metals Pvt. Ltd.:- The registered address of this group company was Flat No-4E, Haripada Plaza, 4th Floor, Plot No-1, Italgacha Road, Dumdum, Kolkata-700079. In connection to this, we visited Kolkata on 01st and 2nd February 2018. The followings facts were observed while doing the inquiry with respect to the companies listed in the Annexure-“A”:- 1. … 7. M/s Mangal Metals Pvt. Ltd.:- The registered address of this group company was Flat No-4E, Haripada Plaza, 4th Floor, Plot No-1, Italgacha Road, Dumdum, Kolkata-700079. When we reached there we found that the building is a five storied in which ground floor was for commercial purpose and others were for the residential purpose. We also found that at the 4t floor of that building, there were only 4 flats available, viz; 4A to 4D serially. Flat No 4E did not exists there. This fact was later confirmed by one of the residents of flat no 2C named “Rana Ji” of that building. He further stated that there is no such business activity of any company is going on from that building. This is for your kind information and necessary direction, if any. (Rajeev Kumar) Inspector of Income Tax Ward-3(1), Bokaro (Rupesh Kumar) Inspector of Income Tax Ward-3(2), Bokaro 11. Whether the second report is a table work or not cannot be adjudicated in this writ petition. Further, whether the company exists or not also cannot be adjudicated in this writ petition. The fact remains that prima facie in view of the aforesaid two inquiry reports, the respondents had reasons to believe that these two companies are shell companies and income derived from these two companies is escaped income so far as this petitioner is concerned. These two reports are sufficient to initiate a proceeding, as there exists sufficient reasons to believe. Whether these reasons are fully proved or not is not to be adjudicated at this stage. Only issue is to see as to whether there are some reasons to believe or not. The sufficiency of the reasons cannot be seen at this stage. There should be some prima facie reasons to believe to proceed in respect of escaped income. We find that respondents had some prima facie material and had some reasons to believe to proceed against the petitioner. A Writ Court exercising certiorari jurisdiction cannot go into the details of the reasons and evaluate the same by putting it in a microscopic scale. 12. In view of what has been held and discussed hereinbefore, we do not find any merit in this writ petition. A Writ Court exercising certiorari jurisdiction cannot go into the details of the reasons and evaluate the same by putting it in a microscopic scale. 12. In view of what has been held and discussed hereinbefore, we do not find any merit in this writ petition. This writ petition is, accordingly, dismissed. 13. Pending interlocutory applications, if any, stand disposed of. 14. There shall be no orders as to costs. Urgent certified copies of this order shall be issued as per the Rules.