The High Court, allowing the assessee’s writ petition against notices of reassessment, held that the notice under section 148 of the Income-tax Act, 1961 had been issued (not served) on April 1, 2021 or on a later date, that since the notice had been dispatched from the Department on or after April 1, 2021 which itself was beyond the period of limitation, the notice issued under section 148, dated March 31, 2021, was barred by limitation under sections 148 and 149, since the notice had left the Income-tax Business Application portal on or after April 1, 2021 and that therefore, it was unsustainable. SLP of revenue was dismissed.