Writ petitions challenged notice under s. 148A(b), order under s. 148A(d), notice under s. 148, assessment under s. 147 read with s. 144B and consequential orders for AYs 2014–15 and 2016–17, pending statutory appeal under s. 246A before the Commissioner (Appeals). The court observed that the appellate authority is bound by the jurisdictional High Court’s decisions, including Hexaware Technologies Ltd. v. Asst. CIT (2024) 464 ITR 430 (Bom)(HC), and therefore the assessee may raise before the Commissioner (Appeals) all pleas argued in the writ petitions-including illegality of the s. 148 notice. The appellate authority must consider those pleas and pass appropriate orders; accordingly, the assessment orders should not be acted upon until appellate proceedings conclude. All contentions were kept open.(AY. 2014-15, 2016-17)