The AO issued three notices u/s 148 dated 31-3-2021, 1-4-2021 and 5-4-2021 seeking to reopen the AY 2013-14 assessment. Concerning the first notice (31-3-2021), the Court held that the time limit of six years had lapsed on 1-4-2020. The decision Ashish Agarwal will not apply, as the decision pertains to the issuances of notice issued on or after 1-04-2021. The Court noted that the two notices, 1-4-2021 and 5-4-2021, were issued without withdrawing the first notice dated 31-3-2021 and were bad in law on account of non-compliance with the mandatory requirements (conducting of prior enquires by the AO) u/s 148A. (AY. 2013-14)