Vide [2022] 443 ITR 191 (Del) an order passed by the AO in disposing of objections against reopening which when does not deal with the submissions and contentions of the assessee is liable to be quashed for certain.
Section 148A orders therefore if they do not so deal with the contentions and submissions too can be challenged in a writ by the taxpayer.
https://dailytaxreporter.com/2022/05/09/failure-to-consider-assessees-submissions-order-disposing-of-its-objections-quashed/
