High Court held that it was mandatory for the Assessing Officer to pass a speaking order taking into consideration not only the material on record but also the reply filed by the assessee to the initial notice under section 148A(b) of the Income-tax Act, 1961 and that the order passed under section 148A(d) for issue of notice under section 148 for reopening the assessment under section 147 was not in accordance with the procedure prescribed under section 148A and hence was unsustainable. SLP of revenue dismissed, having regard to the concession made by the Department in the case of UOI  v. Rajeev Bansal, (2024) 469 ITR 46 (SC(AY. 2015-16)