The HC held that once the petitioner has availed an alternate remedy of filing a substantive appeal, if...

The High Court determined that the petitioner, having opted for an alternate remedy by filing a substantive appeal, must have their contentions regarding the illegality of the Section 148 notice considered by the Appellate and Revisionary Authorities. These authorities are obligated to adhere to the jurisdictional High Court's interpretation in the Hexaware case. Consequently, the assessment order and notices under Sections 148A and 148, which allegedly contravene Sections 151A and 151, are stayed until a decision is rendered by the Appellate or Revisionary Authority. The petitioner is directed to continue proceedings before the Commissioner of Income Tax (Appeals) and the Revisionary Authority, specifically addressing the illegality of the Section 148 notice in accordance with the High Court's ruling in Hexaware. .....

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