Dismissing the writ petition, the Court held that proceedings for reassessment commenced with the issuance of notice under s. 148A(b) on 28-3-2024, which was within the time-limit prescribed under s. 149(1). The assessee’s contention that limitation should be computed from notice dated 22-4-2024 was rejected, as the said notice was issued only in response to the assessee’s reply dated 31-3-2024 and was merely consequential. On a combined reading of the fifth and sixth provisos to s. 149(1), delay, if any, has to be reckoned with reference to the first notice initiating proceedings. Since the initial notice dated 28-3-2024 was within limitation, the Assessing Officer had jurisdiction and the notice under s. 148 dated 30-4-2024 was valid. (AY. 2020-21)