TMI Blog2022 (7) TMI 1459X X X X Extracts X X X X X X X X Extracts X X X X ..... ction 151 it is clear that a notice under Section 148 of the Act, 1961 cannot be issued after the expiry of period of four years from the end of the relevant assessment year, unless the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner was satisfied, on the reasons recorded by the A.O., that it was a ft case for the issue of such a notice. In the prese ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the Respondents. However, with the consent of learned Counsel for the parties, the matter is taken up for final disposal at this stage. 2. The Petitioner challenges the impugned notice dated 29th March, 2021, issued under Section 148 of the Income Tax Act (the Act, 1961) by the Assessing Officer (A.O.), Ward 3(2), Thane, in purported exercise of power vested in it under Section 148 of the Act, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... essment year, unless the Principal Chief Commissioner or Chief Commissioner or Principal Commissioner or Commissioner was satisfied, on the reasons recorded by the A.O., that it was a ft case for the issue of such a notice. In the present case, it is clear that assessment year under consideration was 2015-16 and, therefore, the notice impugned dated 29th March, 2021 was admittedly beyond the fo ..... X X X X Extracts X X X X X X X X Extracts X X X X
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