Allowing the petition the Court held that the notices and order were not in accordance with law as amended by the Finance Act, 2021 ((2021) 432 ITR (St.) 52). In the Supreme Court decision in UOI  v. Rajeev Bansal, (2024) 469 ITR 46 (SC), it had been specifically conceded by the Department that for the assessment year 2015-2016, all the notices issued on or after April 1, 2021 would have to be dropped as they would not fall for completion during the period prescribed under the Taxation and Other Laws (Relaxation of Certain Provisions) Act, 2020. Admittedly, the assessee’s case pertained to the year 2015-2016 and the notice is issued after April 1, 2021. Therefore, it was expected of the Department to act in conformity with the binding dicta of the Supreme Court. Therefore, the order dated July 27, 2022 passed under section 148A(d), the notice dated July 27, 2022 under section 148 and the notice dated December 9, 2024 under section 142(1) for the assessment year 2015-2016 were barred by limitation and hence quashed and set aside.(AY. 2015-16)