Allowing the  petitions the Court held that  that the initial notices issued under section 148A(b) of the Income-tax Act, 1961 having been mailed after June 3, 2022, not only abrogated the mandate of the Central Board of Direct Taxes Instruction No. 1 of 2022 dated May 11, 2022 ([2022] 444 ITR (St.) 43), issued consequent to the judgment in UOI  v. ASHISH AGARWAL (2022) 444 ITR 1 (SC)  but also violated the provisions of section 282A since the name and designation of the concerned officers issuing the notices were not mentioned. The notices under section 148A(b) and the orders under section 148A(d) were unsustainable and therefore, to be set aside. The Department was granted liberty to proceed in accordance with law.(AY.2013-14, 2014-15)