The revenue  relying upon his statement, issued impugned notice dated 24-3-2015 under section 148 seeking to initiate reassessment proceedings for assessment year 1998-99, on the suspicion that the, income of the assessee had escaped assessment. The assessee contended that the limitation for re-assessment for assessment year 1998-99 had expired on 31-3-2005 and therefore, re-assessment was bared by limitation. The Assessing Officer contended that the proceedings were initiated within the extended period of 16 years from the end of the relevant assessment year by relying on section 149(1)(c), introduced by the Finance Act, 2012, with effect from 1-7-2012. On writ allowing the petition the Court held that; reassessment for 1998-99 could not be reopened beyond 31-3-2005 in terms of provisions of section 149 as applicable at the relevant time. The assessees return for assessment year 1998-99 became barred by limitation on 31-3-2005. The question of revival of the period of limitation for reopening assessment for assessment year 1998-99 by taking recourse to the subsequent amendment made in section 149 in the year 2012, i.e., more than 8 years after expiration of limitation on 31-3-2005, has been dealt within K.M. Sharma v. ITO (2002) 254 ITR 772(SC), accordingly the reassessment notice was quashed. (AY. 1998-99)