For the Assessment year  2013-14,  a notice   under section 148 on 25-7-2022  was issued to the petitioner. The Petitioner filed writ petition and  contended that notice was issued beyond limitation as prescribed under provisions of section 149 as would apply to assessment year in question. Court held that as provisions of section 149 would apply, limitation to issue notice under section 148 would expire if four years but not more than six years had elapsed from end of relevant assessment year, as per provisions of section 149(1)(b), as provision stood prior to amendment as incorporated by Finance Act, 2022 brought into effect from 1-4-2022. On facts Section 148 notice was issued on 25-7-2022, which was almost two years after limitation period had expired on 31-3-2020, which was further extended upto 31-3-2021 because of notification issued as result of Covid-19 pandemic. The  Assessing Officer had proceeded without jurisdiction by applying amended provisions of section 149 to case in hand when he issued notice on 25-7-2022 overlooking fact that limitation had already expired on 31-3-2020. Therefore,  reopening notice issued under section 148  is quashed. Followed, New India Assurance Company Ltd v. ACIT (2024) 158 taxmann.com 367 (Bom)(HC)   (AY. 2013-14)