Allowing the  petition the Court held that   the reassessment proceedings had already concluded  and an order had been passed under section 147. The reassessment action was reinitiated on the same set of reasons vide a notice under section 148A(b) of the Act. The right of the Department to reopen the concluded assessment was based on a perceived reading of the decision of the Supreme Court in UOI  v. Ashish Agarwal, (2022) 444 ITR 1 (SC); (2023) 1 SCC 617. In view of the law enunciated by the Delhi High Court in Anindita Sengupta v. Asst. CIT, (2024) 467 ITR 624 (Dehi)(HC) the reinitiation of reassessment was not sustained. The order under section 148A(d) and the consequential notice under section 148 for the assessment year 2014-2015 were quashed.(AY. 2014-15)