Dismissing the petition the court that on an analysis done by the Departmental authorities, they had formed an opinion that the entries found recorded in the electronic books of account of OML were coded.  There was nothing to doubt the prima facie relevancy of the information received by the Departmental authorities for the purpose of initiating the reassessment proceedings. The assessee was not subjected to regular assessment under section 143(3) for the assessment year 2017-2018. Therefore, there was no earlier assessment where the facts being alleged against the assessee or his income had been examined. Reassessment notice was valid. Court also held that the limitation of reassessment proceedings for the assessment year 2017-2018 would exist beyond March 31, 2021. Whether six years or ten years, the reassessment proceedings initiated against the assessee vide notice under section 148 dated March 6, 2024, remained within time limit. (AY. 2017-18)