On the Court held that no time was granted to the assessee by the Assessing Officer to file reply and, therefore, the notice issued under section 148A(b) of the Act was not valid. That the Principal Commissioner had granted the approval to the issuance of notice under section 148 of the Act prior to even digitally signing of the notice under section 148A(b) of the Act as well as to the date of passing of the order under section 148A(d) of the Act on March 26, 2022. That therefore, the notice under section 148 of the Act is issued admittedly without jurisdiction and contrary to the provisions of the Act. The order dated March 26, 2022 passed under section 148A(d) of the Act as well notice dated March 29, 2022 issued under section 148 of the Act were  quashed.(AY. 2018-19)