The High Court held that a reopening notice issued after 31-03-2021 for AY. 2013-14 was barred by limitation. Following its own ruling in New India Assurance Company Ltd. v. ACIT, (2024) 158 taxmann.com 367 (Bom)(HC)  the Court observed that the limitation period under the erstwhile Section 149 to reopen the assessment for AY. 2013-14 had already expired on 31-03-2020. It was held that a right to reopen an assessment, which was already time-barred under the pre-amended Act, could not be revived by subsequent amendments or extensions. Consequently, the impugned notice was rendered invalid and without jurisdiction. (AY. 2013-14)