Notice issued u/s 148 beyond the surviving time available as held by Supreme Court in Rajeev Bansal, is time barred. Applying the principle as laid down by the Hon’ble Supreme Court in Rajeev Bansal case to the instant case the Ld. AO should have issued notice u/s 148 of the Act by 27.06.2022 for AY 2013-14 as only 17 days of limitation survived (14.06.2021 to 30.06.2021). However, the Ld. AO/JAO has issued notice u/s 148 of the Act on 26.07.2022 and therefore, in our view, the notice u/s 148 in the new regime for AY 2013-14 is barred by limitation.