For A.Ys. 2013-14, 2014-15, 2016-17 and 2017-18, the Department had issued old-regime notices under section 148 between 1-4-2021 and 30-6-2021 by taking recourse to the 2020 Act and thereafter issued fresh notices/orders under the new regime between July and September 2022. The High Court held that the dictum of the Supreme Court in UOI  v. Ashish Agarwal(2022) 444 ITR 1 (SC)  had to be followed in letter and spirit. Accordingly, the later notices under the new regime were to be treated as substituted notices, and the validity thereof had to be tested on the basis of the “surviving time” available after excluding the period from 30-6-2021 to 4-5-2022, the time taken for furnishing information under section 148A(b), and 15 days allowed to the assessee for reply. On this basis, the approval granted by the Principal Commissioner under section 151(1) for passing orders under section 148A(d) and issuing notices under section 148 was held to be valid. However, the question of limitation had to be examined separately in each case by computing the surviving time from the date of the original notice issued under the old regime till 30-6-2021. For A.Ys. 2016-17 and 2017-18, old-regime notices issued between 1-4-2021 and 30-6-2021 were to be treated as having been issued within three years from the end of the relevant assessment year, since the three-year period expired during 20-3-2020 to 30-6-2021. Nevertheless, on facts, the impugned orders under section 148A(d) and consequent notices under section 148 had been issued beyond the available “surviving time” and were therefore invalid. The notices, orders under section 148A(d), and all consequential proceedings were quashed. (AY.  2013-14, 2014-15, 2016-17 2017-18)