Held that  the notice issued under section 148 is  issued after March 31, 2021, under the new regime of reassessment, which is  barred by limitation. Hence  all subsequent proceedings on the basis of the notices, being not sustainable in law. Order is quashed. According to the assessee, per its books of account, there is no transactions with the four parties mentioned in the reasons recorded by the Assessing Officer. There is  only one transaction with each of these parties of taking a short-term loan, which was repaid in about two years.  The notice issued by the Assessing Officer under section 148A(b) had been comprehensively replied to controverting the allegations as incorrect and baseless. Assessment is quashed.  (AY. 2014-15, 2016-17)