On writ petitions challenging the notices under section 148A(b) of the Income-tax Act, 1961 and the consequential orders under section 148A(d) for issuing notices under section 148 on the grounds of limitation, not considering the objections filed, not providing a personal hearing, non-application of mind to the facts of each case and several other grounds. Dismissing the petition the Court held that  the contentions of limitation, not considering the objections filed, not providing a personal hearing, non-application of mind to the facts of each case and all other grounds could be raised at a stage when an order was passed under section 147 in the reassessment proceedings and challenged by the assessees if warranted. At that point not only would all the grounds urged before the court be available to the assessees but all other grounds which were not urged before the court would be found necessary to be urged in accordance with law. The authority was to pass orders under section 147 in accordance with law. Decision of Supreme Court is binding. Followed Anshhual Jain v. PCIT (2022) 449 ITR 256 (SC)