Where an initial notice under s. 148A(b), order under s. 148A(d), notice under s. 148 and an assessment order under ss. 147 read with 144 and 144B were challenged while a statutory appeal under s. 246A before the Commissioner (Appeals) and a revision application under s. 264 before the Principal Chief Commissioner were pending, the High Court held that the assessee was entitled to raise all contentions before those statutory fora. The appellate and revisional authorities, being bound by the court’s earlier decisions, must consider legal challenges to the notices and assessment; consequently, the writ court should not pre-empt issues that could be decided by the appellate or revisional authorities. Liberty was therefore granted to the assessee to raise all contentions before those authorities, and the assessment order under ss. 147 read with 144B was directed to remain stayed until conclusion of the pending proceedings.