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The HC held that the conditions u/s 150 were not fulfilled to invoke Section 148 notice beyond the limitation period u/s 149. No finding or direction in the orders of other authorities warranted issuance of Section 148 notice to assess undisclosed income of Rs. 7 crores in assessee's hands. The CIT(A) and ITAT rightly examined the decisions and held that powers u/s 150 could not be invoked to issue Section 148 notice beyond the stipulated period. The HC decided in favour of the assessee.
The HC held that the conditions u/s 150 were not fulfilled to invoke Section 148 notice beyond the limitation period u/s 149. No finding or direction in the orders of other authorities warranted issuance of Section 148 notice to assess undisclosed income of Rs. 7 crores in assessee's hands. The CIT(A) and ITAT rightly examined the decisions and held that powers u/s 150 could not be invoked to issue Section 148 notice beyond the stipulated period. The HC decided in favour of the assessee.
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