High Court held that where the last date for service of notice and initiating proceedings under section 148 under unamended provisions was coming to an end on 31-3-2021, but notices had been issued from the office of the Department either on 1-4-2021 or on subsequent dates, impugned notices were barred by limitation under sections 148 and 149. Court held that two identical matters arising from the High Court had already been dismissed by the instant court in Income-tax Officer, National Faceless Assessment Centre Delhi v. Consortium of Institutions of Higher Learning [2025] 177 taxmann.com 196 (SC) and ACIT v. Anantha Reddy Pannala [2025] 175 taxmann.com 688 (SC), accordingly, the SLP filed by the revenue was dismissed.