On a writ petition challenging the legality, validity and propriety of the notice under section 148A(b) of the Income-tax Act, 1961, the Central Board of Direct Taxes Instruction dated May 11, 2022 ([2022] 444 ITR (St.) 43), the order passed section 148A(d) and the consequent notice issued under unamended section 148. Dismissing the petition, the Court held that  The assessee had an efficacious alternative remedy to challenge the order under section 148A(d) or notice under section 148 in appeal under section 246A before the appellate authority and the ground raised by him with respect to jurisdiction of the authorities could be considered by the authorities. The court would not interfere with the order passed under section 148A(d) and notices issued under section 148A(b) and section 148 since they were issued in pursuance of the judgment of the Supreme Court in UOI  v. Ashish Agarwal(2022) 444 ITR 1 (SC)   Referred, UOI v. Kunisetty Satyanarayana  (2006) 12SCC 28.