The assessee challenged a notice under section 148 issued on 25.07.2022 for AY 2014-15 as being barred by limitation. The High Court held that the validity of a notice must be judged based on the law existing on its date of issue. The Court observed that the time limit for issuing a notice for AY 2014-15 under the pre-amended law had expired on 31.03.2021. As the first proviso to the substituted Section 149 (with effect from 01.04.2021) prohibits the issuance of a notice if it was already time-barred under the old regime, the notice issued on 25.07.2022 was held to be hopelessly barred by limitation and was, accordingly, quashed. (AY. 2014-15)