The High Court held that the notice issued under section 148 on 30-08-2024 was barred by limitation, as the statutory six-year period from the end of the relevant assessment year had expired on 31-03-2021. The Revenue’s SLP was dismissed by the Supreme Court due to an unexplained delay of 327 days in filing and, on merits as well, no ground was found to interfere with the High Court’s order quashing the reassessment notice. SLP of the revenue dismissed on account of delay of 327 days and also on merits. (AY.2014-15)