The last date for service of notice and initiating proceedings under section 148 of the Income-tax Act, 1961 in the case of the assessees was coming to an end on March 31, 2021 and in the majority of the cases, the notice was dated March 31, 2021 but had been issued from the office of the Department either on April 1, 2021 or on subsequent dates, on writ petitions contending that the notices were barred by limitation,  allowing the petitions, that all the notices under section 148 had been issued (not served) on April 1, 2021 or on a later date. The question of service of these notices and the date of service of notices upon the assessees was of no relevance or consequence since the notices had been dispatched from the Department on or after April 1, 2021 which itself was beyond the period of limitation. All the notices issued under section 148, dated March 31, 2021, were barred by limitation under sections 148 and 149, since these notices had left the Income-tax Business Application portal on or after April 1, 2021 and therefore, were unsustainable.