The assessee’s assessment for A.Y. 2017-18 had been completed under section 143(3) pursuant to limited scrutiny. Thereafter, the Assessing Officer sought to reopen the assessment by issuing notice under section 148A(b) on the footing that loans advanced to certain entities and expenditure of Rs. 329 crores had escaped assessment, though all relevant details had already been called for and furnished in the original proceedings. On writ, the Court examined the post-1-4-2021 reassessment scheme and held that after the amendment, section 148 is expressly subject to section 148A, and reassessment cannot be resorted to merely to review a concluded scrutiny assessment. In the absence of any fresh and tangible material available with the Assessing Officer, reopening was without jurisdiction and amounted to an impermissible review of the original order. Accordingly, the notice under section 148A(b), the order under section 148A(d), the consequential notice under section 148 and all further proceedings were quashed. (AY. 2017-18)