VIBHU BAKHRU, J. (ORAL)

1. The petitioner [Assessee] has filed the present petition, inter alia, impugning the following notices/orders:

(i) Notice dated 31.03.2023 issued under Section 148A(b) of the Income Tax Act, 1961 [the Act];

(ii) Corrigendum letter dated 28.04.2023;

(iii) Order dated 27.04.2023 under Section 148(d) of the Act sent by e-mail dated 28.04.2023 at 12:31 AM; and

(iv) Notice dated 27.04.2023 sent by e-mail dated 28.04.2023 at 12:08 AM.

2. It is the petitioner’s case that the notice dated 27.04.2023 issued under Section 148 of the Act [impugned notice] for Assessment Year [AY] 2019-20 is invalid as it was issued beyond the period of limitation. The last date for issuance of the notice was 31.03.2023. After accounting for the exclusion/extensions in terms of provisos to Section 149 of the Act, the period to issue such a notice expired on 27.04.2023 and the impugned notice was sent on 28.04.2023.

3. It is also the petitioner’s case that the impugned notice is invalid as the Assessing Officer [AO] had decided that it was not a fit case for issuance of such a notice and had, on 27.04.2023, passed an order under Section 148A(d) of the Act dropping the said proceedings. Howeve