Assessee filed its return of income, which was accepted and an assessment order was passed. Subsequently, a notice under section 148A(b) was issued against assessee on 2-6-2022, and thereafter an order under section 148A(d) was passed, and a notice under section 148 was issued on 29-7-2022 for reopening assessment. On writ, the Court held that as per the 1st Proviso to section 149, no notice could be issued under section 148 of the new regime if the limitation to issue notice under section 148 of the old regime had already expired. Since notice issued under section 148 of the old regime on 30-6-2021 was issued within the limitation of six years as per TOLA, it was to be treated as a notice under section 148A(b) of the new regime; thus,  notice issued on 29-7-2022 under section 148 of the new regime was in time. Further, since the income that had allegedly escaped assessment was more than Rs. 50 lakhs, the Assessing Officer had time up to 30-6-2025 to issue a notice under section 148 of the new regime (AY. 2014-15)(SJ)