Allowing the petition, the Court held that the first notice issued under section 148 was issued on June 23, 2021, which was six days prior to the expiry of the period of limitation. The time period for issuing a notice under section 148 was extended by following the directions issued by the Supreme Court in UOI  v. Ashish Agarwal, (2022) 444 ITR 1 (SC) and as explained by the Supreme Court in the latter decision in UOI  v. Rajeev Bansal, (2024) 469 ITR 46 (SC). The assessee had responded to the first notice under section 148 which was required to be construed as a notice under section 148A(b) and, therefore the order under section 148A(d) and the second notice under section 148A of the Act were required to be issued within the period of seven days thereafter. The second notice under section 148 was issued beyond the period of limitation. The order holding that the proceedings would continue was set aside. The proceedings which commenced pursuant to the second section 148 notice were also set aside.(AY. 2016-17)