On a writ petition challenging the order under section 148A(d) and the consequent notice under section 148 dated July 29, 2022 for the assessment year 2013-2014 as time barred in view of the first proviso to substituted section 149 as interpreted by the Supreme Court,  allowing the petition, the Court held that  the submission of the Revenue that section 148A(d) extended the time limit under section 149(1) or had a bearing on the time under section 149(1) was misconceived and lacked legal sanctity. The period for reassessment in terms of section 149 of the old regime was deemed to be extended till June 30, 2021 under the 2020 Act. The notice dated June 29, 2021 would be deemed to be notice under section 148A(b). The surviving period excluding the date of re-issuance of notice on June 29, 2021 would be the remainder days in the month of June 2021 (June 30, 2021-June 28, 2021), namely, two days. On June 30, 2021, the extension in terms of the 2020 Act, would come to an end. The period that was excluded would be the period up to June 30, 2021, covered by the provisions of the Income-tax Act read with the 2020 Act, the period from July 1, 2021 to May 3, 2022 being the period before the decision of the Supreme Court in UOI  v. Ashish Agarwal, (2022) 444 ITR 1 (SC), the period from May 4, 2022 till May 20, 2022, the date when the material was furnished and the reasons for reopening were given to the assessee, the period of two weeks for reply to be filed by the assessee, which ended on June 4, 2022 and the extended time to file reply (additional reply was filed by the assessee on June 28, 2022). Further extension was given to the assessee in pursuance of notice dated July 14, 2021 giving additional time of one week in view of change in the incumbent to the office, which period ended on July 21, 2022. On the facts, considering all the exclusion periods, the remainder days for conclusion of the procedure for passing of an order under section 148A(d) and issuance of notice under section 148 would be two days from July 21, 2022 which had expired on July 23, 2022. The notice under section 148 dated July 29, 2022 was time barred. The order under section 148A(d) and the notice issued under section 148, dated July 29, 2022, which were after the surviving period that had expired on July 21, 2022 were beyond the time period specified under section 149(1) and hence quashed. Consequently, the assessment order dated May 29, 2023 passed on the basis of the notice under section 148 was  quashed and set aside. (AY.2013-14)