On writ allowing the petition the Court held  that the initial notice under section 148A(b), the order under section 148A(d) and the notice under section 148 for reopening the assessment under section 147 should not have been issued in a faceless manner, at least till the Supreme Court had decided the special leave petitions pending before it. In spite of the matter having been taken on many occasions, the Supreme Court had not granted any interim protection to the Department. Large number of High Courts had taken a consistent stand that such action of the Department as being violative of the Finance Act, 2020 ((2020) 422 ITR (St.) 25) and Finance Act, 2021 ((2021) 432 ITR (St.) 52). The Department’s persistent initiation of fresh proceedings was contrary to established judicial pronouncements. This court had already provided a balanced approach by preserving both the Department’s rights and the assessee’s interests. The initial notice under section 148A(b), the order under section 148A(d) and the notice under section 148 and consequential orders, if any, were quashed and set aside. Allowing of this writ petition was subject to outcome of the special leave petition preferred by the Department against the decision in Kankanala Ravindra Reddy v. ITO, (2023) 22 ITR-OL 728 (Telangana)(HC)  and either of the parties, could in an appropriate petition seek revival of this writ petition in the light of the decision of the Supreme Court in the pending special leave petition on the very same issue.