The assessee challenged the notice issued on 30-7-2022 to reopen the assessments for the assessment years   2013-14 and 2014-15 are barred by limitation. Allowing the petition the Court held that,

 The Finance Act, 2021, passed on March 28, 2021, and made applicable with effect from April 1, 2021, section 148A was brought into force and section 149 was also recast. The first proviso to section 149 of the Act as introduced by the Finance Act, 2021, inter alia, stipulated that no notice under section 148 shall be issued at any time in a case for the assessment year beginning on or before 1st day of April 2021, if such notice could not have been issued at that time on account of being beyond the time limit specified under the provision as it stood immediately before the commencement of the Finance Act, 2021. Due to the pandemic of 2020 the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020 was passed. Various notifications were issued from time to time extending the time limits prescribed under section 149 of the Act for issuance of reassessment notice under section 148. The 2020 Act is a secondary legislation. Such secondary legislation would not override the principal legislation, the Finance Act, 2021. Therefore, all original notices under section 148 of the Act referable to the old regime and issued between April 1, 2021 and June 30, 2021 which stand beyond the prescribed permissible time limit of six years from the end of assessment year 2013-14 and assessment year 2014-15, would be time barred. Accordingly  all the notices under section 148 of the Act relatable to the assessment year 2013-14 or the assessment year 2014-15, as the case may be, were beyond the permissible time limit, and therefore, liable to be treated as illegal and without jurisdiction.(AY.2013-14, 2014-15)