Dismissing the appeal of the Revenue the Court held that  it was not in dispute that no action had been taken pursuant to notice under section 148 of the Act dated April 18, 2013. The notice related to the assessment year 2008-09. Hence, the second notice dated March 31, 2015 was unsustainable in law. Sub-section (2) of section 153 of the Income-tax Act, 1961 as it stood prior to amendment, relevant to the assessment year 2008-09 provides that no order of assessment, reassessment or re computation shall be made under section 147 after the expiry of one year from the end of the financial year in which the notice under section 148 was served.  Referred  Marwadi Shares and Finance Ltd v. Dy.CIT ß(2018) 4007 ITR 49 (Guj)(HC) (AY.2008-09)