2022 (10) TMI 360

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..... om the end of relevant assessment year and it is also an admitted position which appears from the conclusion of the assessing officer himself in the impugned order that the alleged escapement of income which is below Rs.50 lakh - HELD THAT:- Considering the submission of the parties and admitted factual and legal position which appears on perusal of the impugned order dated 28th July, 2022, impugn .....

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..... 022 under Section 148A(d) of the Income Tax Act, 1961, relating to assessment year 2016-17 on the ground that the same being without jurisdiction and contrary to the provision of Section 149(1)(a) and (b) of the Income Tax Act, 1961 by contending that admittedly the impugned notice has been issued after the expiry of three years from the end of relevant assessment year and it is also an admitted p .....

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