Allowing the petition the Court held that since provisions of Taxation and Other Laws (Relaxation and Amendment of certain Provisions) Act, 2020 applied to pre-amended law as applicable till 31-3-2021 and erstwhile regime of section 148 (applicable up to 31-3-2021) had been repealed by Parliament without any savings and exception clause and was substituted with an altogether new regime vide Finance Act, 2021 with effect from 1-4-2021, notices issued on or after 1-4-2021, relating to assessment years 2013-14 and 2014-15, under section 148 (old) by converting/treating same as under newly inserted section 148A by Finance Act, 2021 which came into effect from 1-4-2021 and all subsequent proceedings on basis of aforesaid notices would not be sustainable in law and are quashed and all legal consequences will follow automatically. Accordingly all the notices issued under S. 148A(b) by the Finance Act, 2021, relating to assessment years 2013-14 and 2014-15, which have been issued on or after Ist April 2021 by extending the time of limitation y the CBDT for issuance of notice under section 148 in exercise of power under S. 3 of TOLA is unauthorised in law and all such notices are barred by limitation and all subsequent proceedings on the basis of the said notices are not sustainable in law.   (AY. 2013-14, 2014-15)