The AO had issued a communication on 24.05.2022 as per directions given by the Supreme Court in the case of UOI v. Ashish Agarwal [2022) 444 ITR1(SC) and called upon the assessee to file a response on or before 8.6.2022. As no response was filed, the AO passed an order under section 148A(d) on 25.07.2022 and issued notice under section 148 on 26.07.2022. The assessee challenged the order and notice, claiming it to be barred by the limitation period prescribed under section 149. Accepting the contentions, the High Court held that notice under Section 148 was required to be issued on or before 08.07.2022 and hence, initiation of reassessment proceedings was clearly barred by limitation. Accordingly, the order passed under Section 148A(d) and the notice issued under Section 148 were quashed (AY. 2013-14)