The assessee had challenged 148A(d) order on ground that said order was passed on grounds which were beyond subject matter of show cause notice issued under section 148A(b), the Court held that as impugned order is at a stage prior to issuance of 148 notice, and unless conditions precedent to invoke the power to reopen assessment had been violated, a Court cannot interfere with preliminary 148A(d) order. The Court also held that the assessee could raise said contentions in reply to 148 notice and thus, no interference would be warranted at this stage. (AY.2015 -16 )