The notifications dated 31-3-2021 and 27-4-2021 issued by the Central Government under section 3(1) of TOLA contained an explanation declaring that the provisions under the old regime shall apply to the reassessment proceedings initiated under them. Thus, the notifications directed the assessing officers to apply the provisions of the old regime for reassessment notices issued after 1-4-2021. The assessing officers accordingly issued reassessment notices between 1-4-2021 and 30-6-2021 by relying on the provisions under section 148 of the old regime. These reassessment notices were challenged by the assessees before various High Courts. The High Courts allowed the writ petitions and quashed all the reassessment notices issued between 1-4-2021 and 30-6-2021 under the old regime on the ground that: (i) Sections 147 to 151 stood substituted by Finance Act, 2021 from 1 April 2021; (ii) In the absence of any saving clause, the Revenue could initiate reassessment proceedings after 1-4-2021 only in accordance with the provisions of the new regime since they were remedial, beneficial, and meant to protect the rights and interests of the assessees; and (iii) the Central Government could not exercise its delegated authority to re-activate the pre-existing law. UOI  v. Ashish Agarwal  (2022) 286 Taxman 183/ 444 ITR 1 (SC)  held that it was in complete agreement with the view taken by various High Courts in holding’ that ‘the benefit of the new provisions shall be made available even in respect of the proceedings relating to past assessment years, provided Section 148 notice has been issued on or after 1-4-2021. However, the Court observed that the Revenue issued the reassessment notices under a bona fide belief that the amendments may not yet have been enforced. The Supreme Court  exercised its discretionary jurisdiction under article 142 in order to balance the interests of the Revenue and the assessees and directed that the reassessment notices issued under the old regime shall be deemed to have been issued under Section 148A(b) of the new regime. On 11-5-2022, the Central Board of Direct Taxes issued an Instruction for the implementation of the decision Ashish Agarwal (supra). The Instruction “clarified” that Ashish Agarwal (supra) will apply to all cases where extended reassessment notices have been issued […] irrespective of the fact whether such notices have been challenged or not. Paragraph 6.1 of the Instruction stated that the reassessment notices will “travel back in time to their original date when such notices were to be issued and then new section 149 of the Act is to be applied at that point. Thus, the Instruction is based on the presumption that the notices issued under Section 148 of the new regime will travel back in time to their original dates, that is, the date when the Section 148 notice under the old regime was issued. Paragraph 6.2 of the Instruction elaborated on the mechanism for issuing notices under section 148 of the new regime. The assessing officers accordingly considered the replies furnished by the assessees and passed orders under section 148A(d). Subsequently, notices under section 148 of the new regime were issued to the assessees by the assessing officers between July and September 2022 for the assessment years 2013-2014, 2014-2015, 2015-2016, 2016-2017, and 2017-2018. These notices were challenged before several High Courts. The High Courts declared the notices to be invalid on the ground that they were: (i) time-barred; and (ii) issued without the appropriate sanction of the specified authority. On the revenue’s appeal to the Supreme Court, on analysing the various provisions the Court held   ; as under ;