Allowing the petition the Court held that that the judgment of the Supreme Court in UOI v.  Ashish Agarwal (2022) 444 ITR 1 (SC)  neither spoke of completed assessments nor did it embody any direction that could be legitimately or justifiably construed as mandating completed assessments being reopened especially where the assessee had raised no objection to the initiation of proceedings. The Assessing Officer had accepted the assessee’s explanation with respect to the issues in respect of the source of investment made in shares and the sale of the immovable property and did not make any additions. It was only thereafter that the notices were issued for the assessment year 2013-14 for which the final assessment order was passed prior to the judgment of the Supreme Court. The Department had proceeded on a perceived understanding of the decision rendered by the Supreme Court and its purport being the recommencement of all proceedings for reassessment under section 147 which stood initiated in terms of notices issued under section 148 after April 1, 2021 and the judgment mandating them to rewind pending proceedings to the stage of section 148A(b). The show-cause notice dated May 30, 2022 issued under section 148A(b), the order dated July 19, 2022 issued under section 148A(d) and the notice dated July 20, 2022 under section 148 were quashed.(AY. 2013-14)