Notice under section 148  dt 30-6-2021  was issued to assessee based on information received pursuant to a survey carried out at premises. The assessee filed its return of income. No reassessment was processed. Pursuant to judgment of Supreme Court in UOI  v. Ashish Agarwal(2022) 286 Taxman 183/444 ITR 1 (SC)revenue  issued reassessment notice under section 148A to assessee dated 27-5-2022 and asserted that said notice was in continuation of original section 148 notice dated 30-6-2021.On writ the Court held that   the  assessee had not instituted any legal proceedings before any Court to assail notice dated 30-6-2021 and, thus, said notice remained unscathed and unimpacted and there arose no need for its revival and, thus, notice under section 148A(b) dated 27-5-2022 was not in continuation or substitution of original notice dated 30-6-2021. Therefore, notice issued on 27-5-2022 for reopening assessment for 2015-16 was in contravention of first proviso to section 149(1) and was barred by limitation.   (AY. 2015-16)