Once the exclusions permitted by Ashish Agarwal and Rajeev Bansal are accounted for, the Revenue must complete the section 148A process and issue the fresh section 148 notice within that surviving period. The entire procedure under section 148A(a) to (d), culminating in the section 148 notice, has to be completed within the overall limitation available under section 149. 148 Notice which is Deemed Notice u/s 148A(b) 30.06.2021 ii. A reassessment notice issued beyond the surviving time limit will be time-barred. ‘” Accordingly, the notice under Section 148A of the IT Act issued on 30/07/2022 was held to be beyond limitation and the same was quashed.