Notice u/s. 148(1) of IT Act when a valid return was pending assessment

RELEVANT PARAGRAPH

16. The term ‘pending’ means ‘undecided1 i.e something which is not concluded. An action is considered as pending from the time of commencement of the proceedings. Thus, a legal proceeding is pending as soon as commenced and until it is concluded. As per Advanced Law Lexicon, third Edition of 2005, page 3521/3522, following are the definitions of the word ‘pending’:
“A suit is pending until final judgment is rendered. See 3