As per case facts, the Petitioner challenged assessment and penalty orders for AY 2014-2015, which arose from a Section 148 notice issued without proper procedure. After Supreme Court directions in ... Ashish Aggarwal, a Section 148A(b) notice was issued, followed by an order and a Section 148 notice. Despite interim relief in an earlier CWP and petitioner's objections, the assessment and penalty proceedings continued. The question arose whether these proceedings were time-barred under the amended Section 149 of the Income Tax Act, 1961, read with TOLA and Supreme Court judgments. Finally, the High Court, citing Union of India Vs. Rajeev Bansal, held that the extended time limit for issuing such notices for AY 2014-2015 had expired before the notice was actually issued. Thus, the assessment order and all subsequent penalty proceedings are set aside.