Assessing Officer issued notice under section 148 (old regime) dated 1-6-2021 seeking to reopen assessment for assessment year 2015-16. Thereafter show cause notice was issued on 17-5-2022. Subsequently, order under section 148A(d) and reopening notice was issued on 30-6-2022. On writ the Court held that  Supreme Court in UOI v. Rajeev Bansal  (2024) 301 Taxman 238/ 469 ITR 46 (SC) had set out concession made on behalf of revenue wherein it was held that for assessment year 2015-16, all notices issued on or after 1-4-2021 would have to be dropped as they would not fall for completion during period prescribed under TOLA Acccordingly the notice and proceedings are quashed and set aside. Refered, Deepak Steel and Power Ltd v.CBDT (2025) 174 taxmann.com 145 (SC) (AY. 2015-16)