The assessee filed its return of income on 3-11-2017. Proceedings were initiated against assessee under section 148 on 21-6-2021. Thereafter, the Assessing Officer issued notice under section 148A(b) on 18-5-2022. In response to said notice, assessee filed a reply on 31-5-2022. Assessing Officer passed an order under section 148A(d) and consequently, a notice under section 148 was issued on the same day. The assessee filed a writ petition. Court held that, in accordance with the new regime, the period for limitation for issuance of notice under the amended section 148 to reopen an assessment is three years but not more than 10 years. As far as assessment year 2017-18 is concerned, the period of limitation for issuance of Notice under section 148 read with section 149, as amended by the Finance Act, 2021 with effect from 1-4-2021, would be till 30-6-2021, instead of 30-3-2021. Since the reply to the notice under section 148A(b) was filed by assessee only on 31-5-2022, the notice issued under section 148 on 30-6-2022 was beyond the limitation period as per the third proviso to section 149(1)(b) as in force with effect from 1-4-2021. Therefore, the reopening notice and consequential orders were quashed and set aside.  (AY. 2017-18)