The assessee filed a writ petition under Article 226 challenging the notice dated 19-03-2024 issued under section 148A(b), the order dated 04-04-2024 passed under section 148A(d), and the consequential notice dated 04-04-2024 issued under section 148 for AY 2013-14, raising the question of limitation under the first proviso to section 149(1).Allowing the petition, the Court held that section 149(1)(b) provides a time of 10 years from the end of the relevant Assessment Year for issuance of notice under section 148. However, the same is subject to the first proviso. A plain reading of the first proviso to section 149(1) makes it clear that it acts as a restriction on the retrospective application of the extended ten-year limitation period. It mandates that for any Assessment Year beginning on or before 01.04.2021, a notice under section 148 cannot be issued at any time if such notice could not have been issued at such time under section 149(1)(b), as it stood immediately before the commencement of the Finance Act, 2021. In the present case, the Court is not concerned with sections 153A and 153C, as reference to such provisions would arise only in search or requisition cases. It is undisputed that the said sections are not relevant here.This issue is no longer res integra. The Hon’ble Supreme Court in UOI v. Rajeev Bansal [2024] 167 taxmann.com 70/301 Taxman 238/469 ITR 46 (SC) has interpreted the first proviso to section 149(1). Applying the ratio of UOI v. Rajeev Bansal (supra) to the facts of the present case, it is evident that for AY 2013-14, the time limit for issuance of notice under section 148 was latest by 30.06.2021. In the present case, the notice is issued on 04.04.2024 and had certainly expired as on 19.03.2024 and as on 04.04.2024. Consequently, by virtue of the first proviso to section 149(1), the Revenue is barred from issuing the notice under section 148 under the new regime, notwithstanding the ten-year period provided in section 149(1)(b) after its amendment by the Finance Act, 2021.  (AY. 2013-14)