On a writ petition challenging the initial notice under section 148A(b), the order under section 148A(d) and the consequential notice under section 148 for reopening the assessment for the assessment year 2017-2018:

Held, allowing the petition, that the period of six years for the relevant assessment year 2017-2018 had expired on March 31, 2024. The notice issued under section 148 thereafter for reopening the assessment under section 147 was barred by limitation. Followed UOI v. Rajeev Bansal (2024) 469 ITR 46 (SC)  (AY.2017-18  )