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Time limit for notices under sections 148 and 148A

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..... e chargeable to tax, which has escaped assessment, amounts to or is likely to amount to fifty lakh rupees or more. (2) No notice to show cause under section 148A shall be issued for the relevant assessment year, (a) if three years have elapsed from the end of the relevant assessment year, unless the case falls under clause (b); (b) if three years, but not more than five years, have elapsed from the end of the relevant assessment year unless the income chargeable to tax which has escaped assessment, as per the information with the Assessing Officer, amounts to or is likely to amount to fifty lakh rupees or more. ] ----------------------- Notes :- 1. Substituted by the Direct Tax Laws (Amendment) Act, 1987, w.e.f. 1-4-1989. 2. Clauses (a) and .....

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..... relevant assessment year, unless the income chargeable to tax which has escaped assessment amounts to or is likely to amount to rupees fifty thousand or more for that year. 3. Inserted vide Finance Act, 2012, w.e.f. 01-07-2012, 4. Substituted vide Finance Act, 2012, w.e.f. 01-07-2012,, before it was read as:- two years 5. Substituted vide THE FINANCE ACT, 2021 dated 28-03-2021 w.e.f. 01-04-2021 before it was read as Time limit for notice. 149. 1 [(1) No notice under section 148 shall be issued for the relevant assessment year,- 2 [( a ) if four years have elapsed from the end of the relevant assessment year, unless the case falls under clause ( b ) 3 [ or clause (c) ] ; ( b ) if four years, but not more than six years, have elapsed from the .....

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..... .f. 01-04-2022 before it was read as (b) if three years, but not more than ten years, have elapsed from the end of the relevant assessment year unless the Assessing Officer has in his possession books of account or other documents or evidence which reveal that the income chargeable to tax, represented in the form of asset, which has escaped assessment amounts to or is likely to amount to fifty lakh rupees or more for that year: 7. Substituted vide Finance Act, 2022 w.e.f. 01-04-2021 before it was read as such notice could not have been issued at that time on account of being beyond the time limit specified under the provisions of clause (b) of sub-section (1) of this section 8. Inserted vide Finance Act, 2022 w.e.f. 01-04-2022 9. Inserted v .....

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..... case may be ] , as they stood immediately before the commencement of the Finance Act, 2021: Provided further that the provisions of this sub-section shall not apply in a case, where a notice under section 153A, or section 153C read with section 153A, is required to be issued in relation to a search initiated under section 132 or books of account, other documents or any assets requisitioned under section 132A, on or before the 31st day of March, 2021: 9 [ Provided also that for cases referred to in clauses (i), (iii) and (iv) of Explanation 2 to section 148, where, (a) a search is initiated under section 132; or (b) a search under section 132 for which the last of authorisations is executed; or (c) requisition is made under section 132A, aft .....

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..... of any court, shall be excluded: Provided also that where immediately after the exclusion of the period referred to in the immediately preceding proviso, the period of limitation available to the Assessing Officer for passing an order under clause (d) of section 148A is 10 [ does not exceed seven days ] , such remaining period shall be extended to seven days and the period of limitation under this sub-section shall be deemed to be extended accordingly. Explanation.-For the purposes of clause (b) of this sub-section, asset shall include immovable property, being land or building or both, shares and securities, loans and advances, deposits in bank account. 8 [ (1A) Notwithstanding anything contained in sub-section (1), where the income charg .....

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