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In [2022] 20 ITR-OL 406 (Del) the Court declined to entertain the petition challenging 148A(d) order on the ground that no assessment order had been passed and it had only been observed that it was a fit case for issuance of notice under section 148 .


However the Court held that the assessee is at liberty to raise all its grounds before the Assessing Officer and the subordinate forums. By this logic such an order can be challenged before Commissioner (appeals) and ITAT and even before the CIT. 

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