https://www.taxtmi.com/caselaws?id=443363 The HC held that a notice under Section 148 read with an order under clause (d) of Section 148A must be issued within three years from the end of the relevant assessment year if the escaped income is below Rs. 50 lakhs. The sixth proviso to Section 149(1) allows extension of time for passing the order under clause (d) of Section 148A if the available period is less than seven days due to limitation constraints. However, the Assessing Officer's time to pass the order under clause (d) of Section 148A, including the one-month period after the assessee's response time, is subject to the overall limitation period under Section 149(1). Any notice under Section 148 without the accompanying order under clause (d) of Section 148A issued beyond the prescribed limitation is invalid and non-compliant with the Act. en-us Tue, 05 Sep 2023 00:00:00 +0530 Sat, 30 May 2026 13:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=443363 The HC held that a notice under Section 148 read with an order under clause (d) of Section 148A must be issued within three years from the end of the relevant assessment year if the escaped income is below Rs. 50 lakhs. The sixth proviso to Section 149(1) allows extension of time for passing the order under clause (d) of Section 148A if the available period is less than seven days due to limitation constraints. However, the Assessing Officer's time to pass the order under clause (d) of Section 148A, including the one-month period after the assessee's response time, is subject to the overall limitation period under Section 149(1). Any notice under Section 148 without the accompanying order under clause (d) of Section 148A issued beyond the prescribed limitation is invalid and non-compliant with the Act. Case-Laws Income Tax Tue, 05 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=443363