On a writ seeking to quash initial notice under s. 148A(b), the order under S. 148A(d), notice under s. 148 and assessment under S. 147 read with S. 144 and 144B and consequential orders, the court directed that the assessee should pursue its statutory appeal under s. 246A before the Commissioner (Appeals) and file an interim application requesting disposal in light of Hexaware  Technologies Ltd v. ACIT (2025) 475 ITR 413 (Bom)(HC). The assessee may raise all contentions in the appeal; the Commissioner (Appeals) should consider any interim application expeditiously. Until the appellate proceedings conclude, the assessment should not be acted upon. All contentions were expressly kept open.