The petitioner challenged the notice issued under S. 148 seeking to reopen AY. 2016-17 pursuant to a search conducted in FY 2022-23. The Court held that once it is accepted that a notice under S. 148 cannot be issued if such notice could not have been issued under S. 153A as applicable to searches conducted prior to 31-3-2021, the limitation prescribed under S. 153A would govern the field. The fourth proviso to S.  153A(1) permits extension up to ten years only where the escaped income is represented in the form of an “asset” as defined in Expln. 2. On facts, the reasons recorded did not allege that the escaped income was represented in the form of any asset such as immovable property, shares, loans, advances or bank deposits; the proposed addition was merely on account of disallowance of expenditure. In absence of material indicating income represented in the form of an asset, the conditions for invoking the extended ten-year period were not satisfied. Consequently, limitation had to be confined to six assessment years preceding AY 2023-24 (the assessment year relevant to the previous year of search). Since AY.2016-17 fell beyond the block of six years, the impugned notice and all proceedings pursuant thereto were set aside. (AY. 2016-17)