Assessing Officer issued a notice under section 148 after amendment of section 149 by Finance Act, 2021 with effect from 1-4-2021 on basis of provisions that existed before amendment seeking to reopen assessment for assessment year 2013-14. Court held that for assessment year 2013-14 time limit to issue a notice under section 148 had already expired on 1-4-2021 and thus, reopening of assessment for assessment year 2013-14 after 31-3-2021 was invalid, without jurisdiction and barred by limitation. Followed New India Assurance Company Ltd. v. Asstt. CIT [2024] 158 taxmann.com 367 (Bom)(HC).  (AY. 2013-14)