Assessing Officer issued a show cause notice under section 148A(b) on 28-3-2022, alleging that an immovable property acquired by assessee revealed that income chargeable to tax represented in the form of an asset had escaped assessment. Thereafter, an order dated 14-4-2022 was passed under section 148A(d). Accordingly, notice under section 148 was issued to assessee on 14-4-2022. The assessee challenged the reopening notice, consequential assessment order and subsequent recovery notices. It was noted that in UOI  v. Rajeev Bansal [2024] 469 ITR 46/301 Taxmann 238 (SC), the revenue had conceded before the Supreme Court that all notices issued on or after 1-4-2021 would have to be dropped as they would not fall for completion during the period prescribed under TOLA. Thus, notice under section 148 and all consequential orders/notices, including recovery notices thereof, were quashed and set aside. (AY. 2015-16)