The Assessing Officer passed an order dated March 31, 2022, to the effect that the reassessment was completed under section 147 read with sections 144 and 144B accepting the income declared by the assessee in the return of income, that credit was given for prepaid taxes and that the demand notice and copy of order were being issued. Thereafter, pursuant to the amendment by the Finance Act, 2021 and the Supreme Court decision in UOI  v. Ashish Agarwal (2022) 444 ITR 1(SC)  the Assessing Officer, under the amended provisions, issued an initial notice dated June 2, 2022 under section 148A(b), passed an order dated July 29, 2022 under section 148A(d) to issue the notice under section 148 which also referred to the earlier notice under the old provisions. On a writ  allowing the petition, that the notice issued under section 148 to reopen the assessment under section 147 following the new procedure was on a change of opinion. The order under section 147 read with sections 144 and 144B and the notice issued under section 142(1) showed that the same set of allegations were made against the assessee, which were the subject matters of the assessment order dated March 31, 2022. The assessment proceedings already stood concluded on March 31, 2022, with regard to various aspects which emanated from the assessee’s return, including the aspects which were the subject matter of the notice dated June 2, 2022, issued under section 148A(b) and the order under section 148A(d). The Assessing Officer could not, under the new regime, reopen the assessment proceedings by traversing the same path and enquire into the same issues which were subject matter of the earlier assessment proceeding. Therefore, the notice, dated June 2, 2022 issued under section 148A(b), the order passed under section 148A(d) and the consequent notice, dated July 29, 2022, issued under section 148 were set aside.(AY.2014-15)