The revenue originally initiated reassessment proceedings against the petitioner under the pre-amended framework via a notice dated 30.06.2021. Following the apex court’s ruling in Ashish Agarwal, the notice was transformed into a section 148A(b) show-cause notice, and after providing additional materials to which the travelling petitioner filed no reply, the Assessing Officer issued a final section 148 notice and section 148A(d) order on 25.07.2022. The petitioner moved a writ petition before the High Court, which officially quashed the reassessment notices on limitation grounds on 03.04.2024. The revenue chose not to appeal this order. However, following the subsequent apex court judgment in Rajeev Bansal, the Assessing Officer issued a notice under section 142(1) on 08.10.2025 and directly finalized a reassessment order on 17.10.2025, adding ` 65,00,000/-to the income on the assumption that Rajeev Bansal revived all such dead notices. Allowing the writ petition, the High Court held that the finality of an un-appealed judgment quashing a notice for a specific assessee cannot be subverted or ignored by the revenue based on a separate judgment passed in another batch of cases. The ruling in Rajeev Bansal did not mandate a sweeping, automated revival of every notice across India where a final court order had already granted a quietus to the litigation. Consequently, the assessment order was entirely devoid of jurisdiction. Even otherwise, applying the exact mathematical criteria for the “surviving period” mapped out in Rajeev Bansal, the revenue only had a balance time-limit of exactly 1 day left to complete its section 148A protocol. Since the petitioner filed no response to the show-cause material, this final 1 day began counting immediately from the day the response window closed (08.06.2022), meaning the revenue’s authority to issue a valid notice under section 148 expired permanently on 09.06.2022. The notice issued on 25.07.2022 was time-barred. (AY. 2014-15)