For AY 2015-16, the assessee received a notice under Section 148 on 25.07.2022, following proceedings initiated under the framework laid down by the Supreme Court in UOI v. Ashish Agarwal(.). The High Court, following its own precedent in Hexaware Technologies Ltd v. ACIT(.)  held that for AY 2015-16, the erstwhile six-year time limit for issuing such a notice had expired on 31.03.2022. The Court observed that the first proviso to the amended Section 149 preserved this original time limit. Accordingly, the notice dated 25.07.2022 was declared to be barred by limitation and without jurisdiction. As the foundational notice was itself illegal, the Court quashed it along with the order under Section 148A(d) and the final assessment order, holding that relegating the assessee to an appeal against a jurisdictionally flawed order would be an empty formality. (AY. 2015-16)