Notice under section 148 dated June 16, 2021 was deemed a section 148A(b) notice per Ashish Agarwal, and after providing material and rejecting objections, a fresh notice under section 148 was issued on July 29, 2022, leading to assessment under section 147 read with section 144B. On appeal, the Tribunal held that since the 4-year limitation period expired within the window covered by the 2020 Act’s extension (up to June 30, 2021), the Revenue had only 15 days from receipt of the assessee’s reply (till June 25, 2022) to issue notice under section 148, but the notice issued on July 29, 2022 came 34 days late; the notice was accordingly barred by limitation under section 149, void ab initio, and the entire reassessment proceedings were quashed. (AY. 2015-16)