Validity of Notice U/s 148 after 4 years from the end of relevant A.Y. without specifying the amount of income escaping assessment

Advertisement Smt. Usha Agarwal Vs ITO (ITAT Agra) Notice u/s 148 of the Act can only be issued if the income escaping assessment amounts to, or is likely to amount to Rs. 1 lac. Non-recording of the reason by the Assessing Officer that the escaped income was likely to be Rs. 1 lac or more was fatal to the issuance of the notice for reassessment. Section 149(1)(b) of the Act states that no notice u/s 148 shall be issued for the relevant assessment year, if four years, but not more than six years, have elapsed from the end of the relevant assessment year, unless the income chargeable to tax ...