Allowing the petition the court held that order  section 148A(d), the consequential notice dated June 30, 2022 under section 148 and the show-cause notice dated March 10, 2025 for the assessment year 2015-2016 were issued to the assessee without following the procedure for issuance of notice in terms of the law as amended by the Finance Act, 2021 ((2021) 432 ITR (St.) 52). The Department had conceded before the Supreme Court in UOI v. Rajeev Bansal, (2024) 469 ITR 46 (SC); 2024 SCC OnLine SC 2693 to the effect that for the assessment year 2015-2016, all notices issued on or after April 1, 2021 would have to be dropped as they would not fall for completion during the period prescribed under the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020. Accordingly, the order dated June 30, 2022 under section 148A(d), the consequential notice dated June 30, 2022 under Section 148 and the show-cause notice dated March 10, 2025 were set aside.(AY.2015-16)