For AY 2016-17, the limitation for issuance of notice under S. 148 under the pre-31-3-2021 regime was four years from the end of the relevant assessment year, i.e., up to 31-3-2021. The first notice dated 23-6-2021 was issued within the extended period up to 30-6-2021 by virtue of TOLA and, in terms of the decision of the Supreme Court in UOI  v. Ashish Agarwal (2022) 326 CTR 473 (SC)  was required to be treated as a notice under S. 148A(b). The assessee filed reply on 7-6-2022. Consequently, the order under S. 148A(d) and the fresh notice under S. 148 were required to be issued within seven days thereafter. However, the second notice under s. 148 was issued on 14-7-2022, which was beyond the prescribed period of limitation. The Revenue’s contention that the second notice was non est on account of proceedings under s. 153C, while simultaneously arguing for revival of abated proceedings under S. 153A, was rejected as intrinsically inconsistent. In view of the definite stand of the Revenue that limitation was four years, the second notice being time-barred, all proceedings pursuant thereto were set aside without examining the issue of parallel proceedings. Ram Balram Buildhome (P) Ltd. v. ITO (2025) 345 CTR  441 (Delhi) (HC) followed. (AY. 2016-17)