AO reopened the assessment and issued notice under section 148A(b) by wrongly treating the share allotment transaction in the Assessment Year, 2013 – 14, whereas the transaction took place in the Financial Year, 2011 – 12. Assessee filed its reply to the said notice as the same is time barred on the date of its issuance. Subsequently, 148A(d) order was passed.  On writ the Court observed that the time limit specified under section 149 was only available in respect to notice under section 148 and not with respect to 148A proceedings. The Court therefore held that the 148A(d) order is a preliminary order and not a final adjudicating order, and hence, the assesse shall be given full opportunity to raise objections during the course of reassessment proceedings.  Petition was dismissed as premature.  (AY. 2013 -14)