The assessee’s return for AY 2017-18 was accepted under section 143(3). Reassessment proceedings were initiated on the basis of audit objection alleging escapement of income exceeding Rs. 329 crores. The assessee challenged the notice under sections 148A(d) and 148, contending that the reopening was based on change of opinion, without fresh material, and was barred by limitation. The High Court held that for notices issued after 1-4-2021, the substituted provisions of section 149 would apply even to past assessment years and, therefore, the notice issued within six years from the end of AY 2017-18 was not time-barred. However, it was held that an audit objection would constitute “information” under section 148(3)(ii) only if it clearly and unambiguously stated that the original assessment was not made in accordance with the provisions of the Act. Since this test was satisfied only in respect of processing charges and legal / professional charges, reopening on all other issues was without jurisdiction. Accordingly, the order under section 148A(d) and notice under section 148 were quashed, and the matter was remanded to the Assessing Officer to issue a fresh notice under section 148A(b) confined only to those specified issues. Matter remanded.(AY. 2017-18)