Assessee filed a writ petition challenging the reopening notice under section 148 dated 29-8-2022 on the ground of limitation. High Court held that, in view of the decision in the case of Keenara Industries Private Limited v. ITO [2023] 147 taxmann.com 585/453 ITR 51 (Guj)(HC), the reopening notice issued against the assessee on 29-8-2022 was quashed. There was a gross delay of 800 and 467 days in filing SLP, which was not satisfactorily explained. SLP filed by the revenue was to be dismissed.  (AY. 2014-15)