The petitioner challenged  the  notice dated 26-5-2022   which was issued under section 148,  to reopen the assessment  for the  assessment year 2014-15 and  also challenged  the order dated 30-6-2022 passed under section 148A(d) of the Act. Notice under section 148 was originally issued on 21-4-2021. The said notice was treated as show-cause notice under section 148A(b), and that thereupon, the order under section 148A(d) was passed. The petitioner contended that the the notice issued under section 148 and the consequential order under section 148A(d) issued by the department  was barred on the ground of limitation as the notice had been issued after passage of six years from the end of the relevant assessment year. Allowing the petition the Court held that   all  notices  they would relate to assessment year 2013-14 or assessment year 2014-15 would be time barred as per provisions of Act as applicable in old regime prior to 1-4-2021.   These notices could not have been issued as per amended provisions of Act. Notice dated 26-5-2022 issued by the Assessing Officer under section 148, seeking to reopen assessment in respect of assessment year 2014-15 and order dated 30-6-2022 passed  under section 148A(d), and all consequential actions, were  quashed and set aside. Notification No. 38 of 2021, dated 27-4-2021.  (AY. 2014-15)