Assessing Officer issued a notice dated 30-6-2021 under section 148 during an extended time period as per TOLA, which was to be treated as a notice under section 148A(b). Thereafter, the Assessing Officer provided information on 27-7-2022. Assessee filed reply on 11-08-2022. Assessing Officer passed an order under section 148A(d) on 29-08-2022, and a notice under section 148 was issued on 30-08-2022.On writ, the Court held that, considering the period of limitation from the date of issuance of notice under section 148 read with TOLA up to 30-6-2021, limitation for issuance of notice under section 148 would be 25-8-2022. Notice dated 30-8-2022 issued under section 148 is issued beyond the ‘surviving time’ and hence invalid. Referred, UOI v. Ashish Agarwal [2022] 286 Taxman 183/444 ITR 1 (SC), UOI v. Rajeev Bansal [2024] 301 Taxman 238/469 ITR 46 (SC).  (AY. 2016-17)