Allowing the petition the Court held that that the  procedure as provided under section 148A was not followed by the Department before issuing notice under section 148. Therefore the entire proceedings and the order under section 147 read with section 144B were in violation of the principles of natural justice and vitiated. The Department was duty bound to comply with the amended provisions of sections 148 and 148A in letter and spirit since they provided safeguards to the assessee. The amended provisions of sections 148 and 148A had come into force with effect from April 1, 2021 and the notice under section 148 had been issued on June 9, 2021 after the amended provisions had come into force. The order under section 147 read with section 144B was set aside. The matter was remitted to the Department for decision afresh treating the notice issued under section 148 as notice under section 148A(b) and to proceed complying with the provisions of section 148A in the light of the decision of the Supreme Court in ASHISH AGARWAL and to pass orders afresh. Matter remanded. Court also held that Existence of alternate remedy is not an absolute bar to the maintainability of writ petition under article 226 of the Constitution of India when there is violation of principle of natural justice. Harbanslal Sahnia v. Indian Oil Corporation Ltd. [2003] 2 SCC 107 and Assistant Commissioner of State    v. Commercial Steel Ltd (2021) 93GSTR 1  (SC)  (AY.2013-14)