For the assessment year 2013-14, the six-year limitation to issue a notice under the unamended section 149 expired on 31.03.2020, and was extended to 31.03.2021 by the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 (TOLA). The High Court held that a notice under section 148 issued in July 2022, pursuant to the Supreme Court’s decision in Union of India v. Ashish Agarwal, was barred by limitation. It reasoned that the first proviso to the new section 149 (with effect from 01.04.2021) prohibits reopening if the time limit under the old law had already expired. Furthermore, the relevant CBDT Notifications under TOLA did not apply to the assessment year 2013-14, as they only extended cases where the original limitation under the Income-tax Act, 1961 (not as extended by TOLA) was ending on 31.03.2021. The High Court noted that the Supreme Court in Ashish Agarwal had expressly preserved all defences available to the assessee under section 149, rendering the notice invalid. (AY. 2013-14)