The assessee, engaged in manufacture and sale of cement, filed ROI for AY 2017–18 claiming deduction u/s 80IA on profits from SWM, WTS and NIPU. The claim was examined in scrutiny and allowed by AO/CIT(A), with quantum partly in dispute before ITAT. During pendency of appeal, survey u/s 133A was conducted (June 2023) and AO alleged fresh facts showed wrong claim of deduction of ₹ 841.25 cr. On 31-3-2024, notice u/s 148A(b) was issued; objections on limitation, change of opinion and non-fulfilment of s. 149(1)(b) conditions were rejected, and notice u/s 148 dated 1-5-2024 was issued by Jurisdictional AO. On writ  the Court held that  following Hexaware Technologies Ltd. v. ACIT  2024] 162 taxmann.com 225/ 464 ITR 430  (Bom.)( HC )  and Godrej Industries Ltd v. ACIT  ( 2024) 338 CTR 25 / 160 taxmann.com 13/ 470 ITR 628  (Bom HC), that for AY 2017–18, the 6-year limit under the erstwhile s. 149(1)(b) expired on 31-3-2024; first proviso to s. 149 bars issue of notice thereafter. Fifth/sixth provisos cannot extend the “restriction” period in the first proviso. Notice dated 1-5-2024 was thus time-barred. Further, under s. 151A and CBDT Notification dt. 29-3-2022, issuance of notice u/s 148 must be through automated allocation by a Faceless AO; issuance by Jurisdictional AO was contrary to the mandatory scheme and without jurisdiction. Consequently, both the notice u/s 148 and the order u/s 148A(d) were quashed. (AY. 2017–18) ( WP No. 10540 /2024 dt .5-8 -2025