Summarize the following court judgment. Civil Appeal No. 2009 of 1978. Appeal by Special Leave from the Judgment and Order dated 8/12th May	 1978 of the Calcutta High Court in Appeal from Original Order No. 884/76. Devi Pal. P. K. Pal	 J. B. Dadachanji and K. J. John for the Appellant. The appellant is a banking company incorporated in the United Kingdom with its registered office at London. It carries on banking business in India	 and is assessed under the Income tax Act	 1961. The appellant filed a return of its income for the assessment year 1972 73. During the assessment proceeding	 the Income tax Officer issued a notice under section 142(1) of the Income tax Act requiring the appellant to produce certain account books and documents. The appellant applied against the notice to the High Court at Calcutta under Articles 226 of the Constitution. A learned Single Judge of the High Court did not accept the wide construction which the appellant sought to put upon the impugned notice	 and construing it in specific limited terms he directed the appellant to comply with it. The appellant preferred an appeal in the High Court. Meanwhile	 pursuant to the direction by the learned Single Judge	 the Income tax Officer made an assessment order on March 31	 1977. Thereafter	 the appeal was allowed by a Division Bench of the High Court by its judgment dated May 8 and 12	 1978	 and the impugned notice under section 142(1) and the 768 consequent assessment order were quashed. But while doing so	 the Division Bench also directed the Income tax Officer to make a fresh assessment. Aggrieved by that direction	 the appellant applied for	 and obtained	 special leave to appeal	 to this Court. The sole question before us is whether the High Court erred in directing a fresh assessment. The appellant contends that the High Court was in error in making the direction because the assessment had already become barred by limitation and thereby a valuable right not to be assessed had accrued to the appellant	 and the High Court was not competent to deprive the appellant of that accrued right. It is necessary first to examine whether the bar of limitation had come into play at any time before the High Court passed the impugned order. The assessment year under consideration is the year 1972 73. By virtue of section 153(1) (a) (iii) of the Income tax Act	 no assessment order in respect of that assessment year could be made after two years from the end of that assessment year. The end of the assessment year is March 31	 1975. However	 the appellant filed the writ petition on March 17	 1975	 fourteen days before the end of the period for making the assessment order. On the same date	 March 17	 1975	 the learned Single Judge granted an interim injunction restraining the Income tax Officer from proceeding with the assessment	 and on March 25	 1975 the injunction was made operative for the pendency of the writ petition. The writ petition was disposed of by the learned single judge by his judgment dated August 31	 1976. It is apparent that the assessment proceedings remained stayed throughout the period from March 17	 1975 to August 31	 1976 by virtue of the orders of the court. As has been mentioned	 the learned Single Judge disposed of the writ petition on August 31	 1976. In his judgment	 besides directing the appellant to comply with the notice under section 142(1) as construed by him	 he also included a direction to the Income tax Officer to complete the assessment by March 31	 1977. On September 22	 1976	 he amended his judgment inasmuch as it now required that "the assessment for the relevant year must be completed on the 31st of March	 1977 but must not be completed before 31st March 1977. " In other words	 while the Income tax Officer could continue with the assessment proceedings he was restrained by the Court from making the assessment order before	 and in fact could make it only on	 March 31	 1977. Now it is important to note that when the amendment was made by the learned Single Judge in his judgment	 it was an amendment made by him to a judgment disposing of the writ petition and having regard especially to the nature and the terms of the amend 769 ment	 it must be deemed to have taken effect as from August 31	 1976	 the date of the original judgment. In the appeal filed thereafter by the appellant	 no interim order was made suspending the operation of the direction that the assessment order be made on March 31	 1977 only. A stay order was made against the enforcement of the notice of demand alone. Adhering to the directions of the learned Single Judge	 the Income tax Officer made an assessment order on March 31	 1977. In the result	 the assessment proceeding remained pending during the entire period from March 17	 1975 to March 31	 1977 by successive orders of the Court. If regard be had to clause (ii) of Explanation 1 to section 153	 which provides that in computing the period of limitation for the purposes of section 153	 the period during which the assessment is stayed by an order or injunction of any court shall be excluded	 it is abundantly clear that the assessment order dated March 31	 1977 is not barred by limitation. In computing the period for making the assessment	 the Income tax Officer would be entitled to exclude the entire period from March 17	 1975	 on which date there were fourteen days still left within the normal operation of the rule of limitation. The assessment order was made on the very first day after the period of stay expired; it could not be faulted on the ground of limitation. There is	 therefore	 no force in the submission of the appellant that the limitation for making the assessment had expired and a valuable right not to be assessed had thereby accrued to it	 and that consequently the High Court was not competent to make the order directing a fresh assessment. The next point is whether the High court possessed any power to make the order directing a fresh assessment. The principal relief sought in the writ petition was the quashing of the notice under section 142(1) of the Income tax Act	 and inasmuch as the assessment order dated March 31	 1977 was made during the pendency of the proceeding consequent upon a purported non compliance with that notice	 it became necessary to obtain the quashing of the assessment order also. The character of an assessment proceeding	 of which the impugned notice and the assessment order formed part	 being quasi judicial	 the "certiorari" jurisdiction of the High court under Article 226 was attracted. Ordinarily	 where the High court exercises such jurisdiction it merely quashes the offending order and the consequential legal effect is that but for the offending order the remaining part of the proceeding stands automatically revived before the inferior court or tribunal with the need for fresh consideration and disposal by a fresh order. Ordinarily	 the High Court does not substitute its own order for the order quashed by it. It is	 of course	 a different case where the adjudication by the High Court establishes a complete want of jurisdic 770 tion in the inferior court or tribunal to entertain or to take the proceeding at all. In that event on the quashing of the proceeding by the High Court there is no revival at all. But although in the former kind of case the High court	 after quashing the offending order	 does not substitute its own order it has power nonetheless to pass such further orders as the justice of the case requires. When passing such orders the High court draws on its inherent power to make all such orders as are necessary for doing complete justice between the parties. The interests of justice require that any undeserved or unfair advantage gained by a party invoking the jurisdiction of the court	 by the mere circumstance that it has initiated a proceeding in the court	 must be neutralised. The simple fact of the institution of litigation by itself should not be permitted to confer an advantage on the party responsible for it. The present case goes further. The appellant would not have enjoyed the advantage of the bar of limitation if	 notwithstanding his immediate grievance against the notice under section 142(1) of the Income tax Act	 he had permitted the assessment proceeding to go on after registering his protest before the Income tax Officer	 and allowed an assessment order to be made in the normal course. In an application under section 146 against the assessment order	 it would have been open to him to urge that the notice was unreasonable and invalid and he was prevented by sufficient cause from complying with it and therefore the assessment order should be cancelled. In that event	 the fresh assessment made under section 146 would not be fettered by the bar of limitation. Section 153(3)(i) removes the bar. But the appellant preferred the constitutional jurisdiction of the High Court under Article 226. If no order was made by the High Court directing a fresh assessment	 he could contend as is the contention now before us	 that a fresh assessment proceeding is barred by limitation. That is an advantage which the appellant seeks to derive by the mere circumstance of his filing a writ petition. It will be noted that the defect complained of by the appellant in the notice was a procedural lapse at best and one that could be readily corrected by serving an appropriate notice. It was not a defect effecting the fundamental jurisdiction of the Income tax Officer to make the assessment. In our opinion	 the High Court was plainly right in making the direction which it did. The observations of this court in Director of Inspection of Income tax (Investigation)	 New Delhi and Another vs Pooran Mall & Sons and another(1) are relevant. It said: "The court in exercising its powers under article 226 has to mould the remedy to suit the facts of a case. If in a particular case a court takes the view that the Income tax 771 Officer	 while passing an order under section 132(5)	 did not give an adequate opportunity to the party concerned it should not be left with the only option of quashing it and putting the party at an advantage even though it may be satisfied that on the material before him the conclusion arrived at by the Income tax Officer was correct or dismissing the petition because otherwise the party would get an unfair advantage. The power to quash an order under Article 226 can be exercised not merely when the order sought to be quashed is one made without jurisdiction in which case there can be no room for the same authority to be directed to deal with it. But	 in the circumstances of a case	 the court might take the view that another authority has the jurisdiction to deal with the matter and may direct that authority to deal with it or where the order of the authority which has the jurisdiction is vitiated by circumstances like failure to observe the principles of natural justice	 the court may quash the order and direct the authority to dispose of the matter afresh after giving the aggrieved party a reasonable opportunity of putting forward its case. Otherwise	 it would mean that where a court quashes an order because the principles of natural justice have not been complied with	 it should not while passing that order permit the tribunal or the authority to deal with it again irrespective of the merits of the case. " The point was considered by the Calcutta High court in Cachar plywood Ltd. vs Income Tax Officer	 "A" Ward	 Karimganj	 Dist.	 Cachar & Another(1) and the High court	 after considering the provisions of section 153 of the Income Tax Act	 considered it appropriate	 while disposing of the writ petition	 to issue a direction to the Income tax Officer to complete the assessment which	 but for the direction of the High court	 would have been barred by limitation. Our attention has been drawn to a recent decision of this Court in Rajinder Nath etc. vs The Commissioner of Income tax	 Delhi(2) (by a Bench of this Court of which one of us was a member). In that case	 the Court considered the provisions of section 153(3) (ii) of the Income tax Act and laid down that the word "direction" in that subsection refers to a direction necessary for the disposal of the case and which the court has power to make while deciding the case. In the view taken by us that the order made by the High Court directing a fresh assessment is necessary for properly and completely disposing of 772 the writ petition	 the appellant can obtain no assistance from Rajinder Nath (supra). Mr. A. P. Mohanti	 who appeared for the intervener	 supported the contention that the High Court was not entitled to make an order directing a fresh assessment	 and has referred us to three cases	 Pickles vs Falsham	(1)	 Anisminic Ltd. vs The Foreign Compensation Commission and Another(2)	 and Bath and West Countries Property Trust Ltd. vs Thomas (Inspector of Taxes)(3). We are of the opinion that the cases are distinguishable. In Pickles (supra)	 Cave L.C. declined to remand the case to the Special Commissioners because the time for making the requisite assessment had expired. In Anisminic Ltd. (supra) the decision of the Commissioner considered by the House of Lords was a nullity. The present case is one of a mere procedural lapse	 an imperfect notice which is replaceable by a proper notice. The third case	 Bath and West Countries Property Trust Ltd. (supra) was again a case where it was too late for the Inspector to make a fresh assessment. In the case before us a direction by the High court is sufficient to raise the bar of limitation	 a power absent in the aforesaid cases. In our Judgment	 the order made by the High Court directing the Income tax Officer to make a fresh assessment was necessary in order to do complete justice between the parties. The High Court had jurisdiction to make the order	 and it acted in the sound exercise of its judicial discretion in making it. The appeal is dismissed with costs. V.D.K. Appeal dismissed.

The appellant	 a banking company incorporated in the United Kingdom	 carries on banking business in India and is assessed under the Income Tax Act	 1961. The appellant filed a return of its income for the assessment year 1972 73. During the assessment proceedings the Income Tax Officer issued a notice under section 142(1) of the Income Tax Act requiring the appellant to produce certain account books and documents. The appellant applied against the notice to the High Court of Calcutta under Article 226 of the Constitution. The High Court construing the notice in specifically limited terms directed the appellant to comply with it. The appellant preferred an appeal in the High Court. Meanwhile	 pursuant to the direction by the learned single judge	 the Income Tax Officer made an assessment order on March 31	 1977. Thereafter the appeal was allowed by a Division Bench of the High Court by its judgment dated May 8 and 12	 1978	 and the impugned notice under section 142(1) and the consequent assessment order were quashed. But while doing so	 the Division Bench also directed the Income Tax Officer to make a fresh assessment. Aggrieved by that direction	 the appellant applied for	 and obtained special leave to appeal to this Court. Dismissing the appeal	 the Court ^ HELD: 1. The High Court was competent to make the order directing a fresh assessment since the limitation for making the assessment had not expired and no valuable right to be assessed had thereby accrued to the appellant. [769 D E] The facts of the case make it clear that the assessment proceedings remained pending during the entire period from March 17	 1975 to March 31	 1977 by virtue of successive stay orders of the Court. If regard be had to clause (ii) of Explanation 1 to section 153 which provides that in computing the period of limitation for the purposes of section 153 the period during which the assessment is stayed by an order or injunction of any court shall be excluded	 it is abundantly clear that the assessment order dated March 31	 1977 is not barred by limitation. In computing the period for making the assessment	 the Income Tax Officer would be entitled to exclude the entire period from March 17	 1975	 on which date there were fourteen days still left within the normal 766 operation of the rule of limitation. The assessment order was made on the very first day after the period of stay expired; it could not be faulted on the ground of limitation. [769 B D] 2. The character of an assessment proceeding of which the impugned notice and the assessment order formed part	 being quasi judicial	 the "certiorari" jurisdiction of the High Court under Article 226 was attracted. Ordinarily	 where the High Court exercises such jurisdiction it merely quashes the offending order	 and the consequential legal effect is that but for the offending order the remaining part of the proceeding stands automatically reviewed before the inferior court or tribunal with the need for fresh consideration and disposal by a fresh order. Ordinarily the High Court does not substitute its own order for the order quashed by it. It is	 of course	 a different case where the adjudication by the High Court establishes a complete want of jurisdiction in the inferior court or tribunal to entertain or to take the proceeding at all. In that event on the quashing of the proceeding by the High Court there is no revival at all. But although in the former kind of case the High Court	 after quashing the offending order	 does not substitute its own order it has power nonetheless to pass such further orders as the justice of the case requires. [769 F H	 770 A] 3. When passing such orders the High Court draws on its inherent power to make all such orders as are necessary for doing complete justice between the parties. The interests of justice require that any undeserved or unfair advantage gained by a party invoking the jurisdiction of the court	 by the mere circumstance that it has initiated a proceeding in the court	 must be neutralised. The simple fact of the institution of litigation by itself should not be permitted to confer an advantage on the party responsible for it. [770 A C] In the present case	 the appellant would not have enjoyed the advantage of the bar of limitation if	 notwithstanding his immediate grievance against the notice under section 142(1) of the Income Tax Act	 he had permitted the assessment proceeding to go on after registering his protest before the Income Tax Officer	 and allowed an assessment order to be made in the normal course. In an application under section 146 against the assessment order	 it would have been open to him to urge that the notice was unreasonable and invalid and he was prevented by sufficient cause from complying with it and therefore the assessment order should be cancelled. In that event	 the fresh assessment made under section 146 would not be fettered by the bar of limitation. Section 153(3)(i) removes the bar. But the appellant preferred the constitutional jurisdiction of the High Court under Article 226. If no order was made by the High Court directing a fresh assessment	 he could contend that a fresh assessment proceeding is barred by limitation. That is an advantage which the appellant seeks to derive by the mere circumstance of his filing a writ petition. It will be noted that the defect complained of by the appellant in the notice was a procedural lapse at best and one that could be readily corrected by serving an appropriate notice. It was not a defect affecting the fundamental jurisdiction of the Income Tax Officer to make the assessment. The High Court was plainly right in making the direction which it did. [770 C G] Director of Inspection of Income Tax (Investigation) New Delhi and Anr. vs Pooran Mall and Sons and Anr. @ 395; followed. 767 Cachar Plywood Ltd. vs Income Tax Officer	 'A ' Ward	 Karimganj Dist. Cachar and Anr.	 (1978) 114 ITR (Cal.); approved. Rajinder Nath etc. vs The Commissioner of Income Tax	 Delhi	 ; distinguished. Pickles vs Falsham	 9 Tax Cases	 261	 288; Anisminic Ltd. vs The Foreign Compensation Commission & Anr. [1969] 1 All E.L.R. 208; Bath and West Countries Property Trust Ltd. vs Thomas (Inspector of Taxes) ; distinguished.