Held that as per  Finance Act, 2021 notice under section 148 of the Income-tax Act, 1961 cannot be issued at any time for the relevant assessment year beginning on or before the April 1, 2021, if such notice could not have been issued at that time on account of being beyond the time-limit prescribed under clause 149(1)(b) thereof, as it stood immediately before the proposed amendment. What could not be done earlier, cannot be done even after the amendment. That is, if the notice is barred by limitation then, in the amended provision also, the notice is barred by limitation.  Show cause notice u/s 148A(b) was issued on 24-5-2022, asking to furnish reply by June 8, 2022.Filed reply on 8 th June 2022, Notice under section 148 was issued on July 31 st 2022. Even after assuming a period of 27 days (i. e. 16 days from 24^th May to 8 th June and 11 days from 28 th June to 8 th July) are excluded from the date of notice under section 148 issued on July 31, 2022 is barred by limitation.  (AY. 2014-15)