Allowing the petition the Court held that the assessee had taken an emphatic stand that the bank accounts adverted to by the Assessing Officer did not belong to him.  The assessee  had furnished the statement of accounts of the two banks which were maintained by him. However  without any actionable material, the Assessing Officer had decided to reopen, in a sense, a closed assessment which had reached culmination via order dated March 22, 2022, at least at the point in time when notice under section 148A(b) of the Act was issued. Accordingly the issue of notice under amended provision on same issue is not valid. Order and notice is quashed.  (AY. 2015-16)