As per case facts, the petitioner was issued a Section 148 notice after April 1, 2021. Following a Supreme Court judgment, this notice was deemed a Section 148A(b) show cause ... notice, leading to an order under Section 148A(d) and a consequential Section 148 notice for AY 2015-16. The petitioner challenged these, arguing they were barred by limitation under Section 149 of the Income Tax Act, citing the Supreme Court's `Rajeev Bansal` judgment. The question arose whether the reassessment proceedings initiated by notices for AY 2015-16, issued on or after April 1, 2021, were barred by limitation. Finally, the High Court, acknowledging the Revenue's concession in `Rajeev Bansal` for AY 2015-16, found the order and notices for that Assessment Year to be time-barred and set them aside.