Assessee, received a notice under section 148 on 09.03.2021 for reopening assessment for relevant assessment years. Assessee responded by filing a return and requested reasons for reopening.Revenue admitted that a technical glitch caused assessee’s return and request for reopening reasons to go unnoticed by Assessment Officer, leading to issuance of assessment orders under Section 144 r/w Section 147 for relevant assessment years on 03.03.2022. Assessee filed writ petitions to quash assessment orders and to stay demand.High Court set aside assessment orders dated 03.03.2022 but remanded matters back to jurisdictional Assessing Officer for passing fresh assessment orders. Assessee filed a review petition, contending that remand was contrary to law laid down in UOI v. Ashish Agarwal [2022] 138 taxmann.com 64/286 Taxman 183/444 ITR 1 (SC) and GKN Driveshafts (India) Ltd. v. ITO [2002] 125 Taxman 963/[2003] 259 ITR 19 (SC). It was noted that where notice under section 148 of unamended Act was sent to assessee prior to 1-04-2021, and return filed and application seeking reasons for reopening was requested after 1-04-2021, law laid down in Ashish Agarwal (supra) would not apply and come to laid of assessee in seeking review of order. Further in GKN Driveshafts (India) Ltd. case (supra) Supreme Court noted that procedural lapse due to a system glitch did not invalidate entire proceeding. Therefore, there was no ground made out for review of common order and submissions made were more in nature of seeking reappreciation of entire matter on its merits, which was impermissible in review jurisdiction. (AY. 2013-14, 2014-15, 2015-16, 2018-19)