s.148 notice beyond 4 years without compliance of s.147 & s.151(2) not valid

Whether notice issued beyond four year under section 148 of Income tax Act, without compliance of the mandatory requirements of section 147 and 151(2) is valid.

The notice under section 148 can be issued beyond four year with prior approval of joint commissioner and at the same time joint-commissioner should be satisfied that this is fit case for issue of a notice in view of section 151(2). In the present case no new evidence or fresh evidence produce by assess

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