Court held that procedure laid out in UOI v. Ashish Agarwal 2022) 326 CTR  473 /  213 DTR  217 (SC)  clearly stood confined to matters where although notices may have been issued, proceedings were yet to have attained finality. This clearly flows from the impugned notices being ordained to be treated as show-cause notices under S. 148A(b) and the concomitant liberty being accorded to AOs to proceed further in accordance with S. 148A(d). Supreme Court was faced with a peculiar and an unprecedented situation where the Revenue was rendered remediless to assess escaped income even though material may have merited such an action being pursued solely on account of a misinterpretation of the correct legal position. It was these factors which clearly appear to have weighed upon the Supreme Court to mould and sculpt a procedure which would strike a just balance between competing interests. Ashish Agarwal cannot possibly be read as mandating the hands of the clock being rewound and reversing final decisions which may have come to be rendered in the interregnum.  Regard must also be had to the undisputed fact that the assessee never questioned the validity of the original notices on grounds which were urged before the various High Courts and where assessees had questioned the invocation of the unamended provisions. Accordingly there was  no justification for the respondent to have issued notices afresh seeking to reopen proceedings which had been rendered a closure prior to the judgment rendered in Ashish Agarwal. Accordingly the notice and order disposing the objection is quashed.  (AY. 2013-14)