Assessing Officer initiated reassessment proceedings pursuant to notice issued under section 148 on 5-4-2022. High Court, vide its order dated 9-5-2024, allowed the writ petition. However, the Assessing Officer continued with reassessment on premises that order passed by the Supreme Court in case of UOI  v. Rajeev Bansal [2024] 301 Taxman 238/  469 ITR 46 (SC) would be applicable in the facts of the case of the petitioner. Court held that the Assessing Officer overlooked the fact that, in view of the decision of the High Court in Hexaware Technologies Limited v. ACIT [2024] 162 taxmann.com 225 /464 ITR 430 (Bom)(HC), he could not have proceeded further.  Both parties agreed that, in view of the decision of the High Court in Hexaware (supra), the assessment order dated 3-3-2025 was bad in law. However, revenue contended that, as per his reading of Rajeev Bansal (supra), though a concession had been made by ASG in respect of assessment year 2015-16, said concession did not appear to have been judicially recognised by the Supreme Court.   Since notice under section 148 was undisputedly issued on 5-4-2022, which was after 1-4-2021, said reassessment proceedings ought to have been dropped in view of the concession made by Additional Solicitor General before the Supreme Court as recorded in Rajeev Bansal (supra). Notice being barred by limitation was to be dropped, and consequently impugned reassessment order, demand notice and penalty notices were to be quashed and set aside.  (AY. 2015-16)