Allowing the petition the Court held that Co-ordinate Bench had set aside and quashed both notices respectively dt. 31st March, 2021 and 8th April, 2021, issued under s. 148. Revenue was left to proceed in accordance with law. Revenue did proceed. However, in issuing  show-cause notice for effecting the variation, Revenue did not comply with the amended provision of S.  148A inserted by the Finance Act, 2021. Keeping in mind that the earlier notices under s. 148 were quashed, in the facts and circumstances Revenue had to proceed from the stage of S.  148A(b), on dispensation of inquiry as directed by the Supreme Court in UOI  v. Ashish Agarwal (2022) 326 CTR 473 / 213 DTR  217(SC), the assessee had right to reply to the show-cause, consideration of which may have led to an order passed under S. 148A(d), for issuance of notice under S. 148 subsequent thereto. The assessee would then have had to comply on filing return for the reassessment. This procedure was not followed. Impugned show-cause notice dt. 3rd May, 2023, assessment order dt. 12th May, 2023 and demand also dt. 12th May, 2023 are set aside and quashed. The reservation by said judgment dt. 18th Nov., 2022, in para 12 thereof is reiterated for Revenue to move in accordance with law. For purposes of moving forward with the reassessment, Revenue has to issue fresh notice under S. 148A(b). This is because the earlier notices issued stood quashed by Co ordinate Bench and, therefore cannot be said to be notices deemed to have been issued under S.  148A.Acccordingly the notices and orders are quashed.  (AY.  2015-16, 2016-17)