Allowing the petition the Court held that  the notices dated June 1, 2022 and July 16, 2022, issued under section 148A(b) and section 148, respectively and the order dated July 16, 2022 passed under section 148A(d) were liable to be quashed. The procedure envisaged in Union of India v. Ashish Agarwal, (2022) 444 ITR 1 (SC) is unambiguously confined to matters where although notices may have been issued, proceedings were yet to attain finality. Judgment neither spoke of completed assessments nor did it embody any direction that could be legitimately or justifiably construed as mandating completed assessments being reopened. (AY. 2015-16)