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

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 elap

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