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“Section 149(1)”

Section References (mined)Section 149Section 149(1)891 judgments

The decision most relied on for Section 149(1) is Union of India v. Ashish Agarwal (444 ITR 1), cited in 524 judgments on BharatTax.

Leading authorities on Section 149(1)

Union of India v. Ashish Agarwal
444 ITR 1 · 2022 · Supreme Court
524
citing judgments

Notices issued under the unamended Section 148 of the Income-tax Act between April 1, 2021, and May 4, 2022, must be treated as notices issued under the new Section 148A(b) of the amended law. This requires the Assessing Officer to follow the procedure prescribed under the amended reassessment provisions, including issuing an order under Section 148A(d) before a fresh notice under Section 148.

PCIT v. Ojjus Medicare (P) Ltd.
465 ITR 101 · 2024 · High Court
277
citing judgments

For assessments under Section 153C, the commencement point for calculating the six or ten assessment year block period is the date of issuing the Section 153C notice, or the date of the satisfaction note/handing over of books, as clarified by the first proviso to Section 153C(1).

CIT v. Mithila Motor's (P.) Ltd.
149 ITR 751 · 1984 · High Court
248
citing judgments

Minor defects or mistakes in a penalty notice issued under Section 274 do not invalidate penalty proceedings under Section 271(1)(c) if the assessee suffers no prejudice and is aware of the charge. However, significant vagueness or ambiguity that demonstrates non-application of mind or causes prejudice can still render the notice invalid.

Haryana Acrylic Manufacturing Company v. CIT
308 ITR 38 · 2009 · High Court
248
citing judgments

Reassessment proceedings are invalid if the reasons recorded for initiating action under section 148 are not served on the assessee within the limitation period prescribed by section 149. Furthermore, reassessment cannot be based on a mere change of opinion without tangible material, particularly when the assessee has made a full and true disclosure of material facts.

K.P.Madhusudhanan v. CIT
251 ITR 99 · 2001 · Supreme Court
199
citing judgments

Voluntary disclosures or explanations offered by an assessee do not automatically absolve them from penalty under section 271(1)(c) if the explanation is not substantiated by credible evidence.

535 (Del); 6. Tata Teleservices v. UOI
385 ITR 497 · 2016 · High Court
163
citing judgments

Orders passed under section 201(1) are barred by limitation if the prescribed period of limitation under section 201(3) had expired before the amendment by the Finance Act, 2014 came into force. The amended section 201(3) does not apply retrospectively.

1. S. S. Gadgil v. Lal & Co.
53 ITR 231 · 1964 · Supreme Court
158
citing judgments

Income-tax assessment proceedings are administrative in nature, not civil disputes or judicial proceedings between contesting parties. Income-tax authorities act as administrative bodies to estimate income and assess tax, and the proper service of notice within the limitation period is foundational for reassessment jurisdiction.

Parimisetti Seetharamamma v. CIT
57 ITR 532 · 1965 · Supreme Court
142
citing judgments

Not all receipts constitute income chargeable to tax. An Assessing Officer cannot reject a prima facie reasonable explanation on mere probabilities or arbitrary grounds, but must disprove facts.

Judgments citing Section 149(1)

Exel Rubber Private Limited, K.V.Rangareddy vs. ACIT., Central Circle-1(2), Hyderabad

ITA 1109/HYD/2025[2018-19]Status: DisposedITAT Hyderabad24 Sept 2025AY 2018-19

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

For Appellant: Shri M.V. Prasad, CA
Section 132Section 143(3)Section 147Section 148Section 148BSection 149Section 149(1)(b)Section 151

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly ... condition as stipulated u/s 149(1)(b) of the Act are satisfied or not. For ready reference, section 149(1) of the Act is reproduced as under: “149. (1) No notice under section 148 shall be issued for the relevant assessment year, (a) if three years have elapsed from

Exel Rubber Private Limited, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

ITA 1108/HYD/2025[2017-18]Status: DisposedITAT Hyderabad24 Sept 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

For Appellant: Shri M.V. Prasad, CA
Section 132Section 143(3)Section 147Section 148Section 148BSection 149Section 149(1)(b)Section 151

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly ... condition as stipulated u/s 149(1)(b) of the Act are satisfied or not. For ready reference, section 149(1) of the Act is reprodued as under: “149. (1) No notice under section 148 shall be issued for the relevant assessment year, (a) if three years have elapsed from

Exel Rubber Private Limited, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

ITA 1107/HYD/2025[2016-17]Status: DisposedITAT Hyderabad24 Sept 2025AY 2016-17

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

For Appellant: Shri M.V. Prasad, CA
Section 132Section 143(3)Section 147Section 148Section 148BSection 149Section 149(1)(b)Section 151

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly

Exel Rubber Private Limited, Hyderabad vs. ACIT., Central Circle-1(2), Hyderabad

ITA 1106/HYD/2025[2015-16]Status: DisposedITAT Hyderabad24 Sept 2025AY 2015-16
For Appellant: Shri M.V. Prasad, CA
Section 132Section 143(3)Section 147Section 148Section 148BSection 149Section 149(1)(b)Section 151

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly

Ace Tyres Private Limited, Hyderabad vs. ACIT., Central Circle-1(2), Hyderabad

ITA 1088/HYD/2025[2018-19]Status: DisposedITAT Hyderabad24 Sept 2025AY 2018-19

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

For Appellant: Shri M.V.Prasad, CAFor Respondent: : Dr. Sachin Kumar, Sr. AR
Section 132Section 143(3)Section 148Section 148BSection 149Section 149(1)(b)Section 151

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly, impugned ... circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(iii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly, impugned

Ace Tyres Private Limited, Hyderabad vs. DCIT., Central Circle-1(2), Hyderabad

ITA 1087/HYD/2025[2017-18]Status: DisposedITAT Hyderabad24 Sept 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

Section 132Section 143(3)Section 148Section 148BSection 149Section 149(1)(b)Section 151

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly Page 2 of 78 grant of sanction is liable to be declared as nullity ... circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(iii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly, impugned

Ace Tyres Private Limited, Hyderabad vs. ACIT., Central Circle-1(2), Hyderabad

ITA 1086/HYD/2025[2016-17]Status: DisposedITAT Hyderabad24 Sept 2025AY 2016-17

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

For Appellant: Shri M.V.Prasad, CAFor Respondent: : Dr. Sachin Kumar, Sr. AR
Section 132Section 143(3)Section 148Section 148BSection 149Section 149(1)(b)Section 151

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly Page 2 of 78 grant of sanction is liable to be declared as nullity ... circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(iii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly, impugned

Ace Tyres Private Limited, Hyderabad vs. ACIT., Central Circle-1(2), Hyderabad

ITA 1085/HYD/2025[2015-16]Status: DisposedITAT Hyderabad24 Sept 2025AY 2015-16

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.आ.अपी.सं / Ita Nos.1084 To 1088 & 1027/Hyd/2025 (निर्धारण वर्ष/Assessment Years: 2014-15 To 2019-20)

For Appellant: Shri M.V.Prasad, CAFor Respondent: : Dr. Sachin Kumar, Sr. AR
Section 132Section 143(3)Section 148Section 148BSection 149Section 149(1)(b)Section 151

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly, impugned ... circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(iii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly, impugned

Ace Tyres Private Limited, Hyderabad vs. ACIT., Central Circle-1(2), Hyderabad

ITA 1084/HYD/2025[2014-15]Status: DisposedITAT Hyderabad24 Sept 2025AY 2014-15

Bench: Shri Vijay Pal Rao, Vice- & Shri Manjunatha, G.

For Appellant: Shri M.V.Prasad, CAFor Respondent: : Dr. Sachin Kumar, Sr. AR
Section 132Section 143(3)Section 148Section 148BSection 149Section 149(1)(b)Section 151

circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(ii). Accordingly Page 2 of 78 grant of sanction is liable to be declared as nullity ... circumstance of the case, sanction under Section 151 of the Act, has been granted mechanically and without satisfaction that how it fits under Section 149(1)(b)(i) and Section 149(1)(b)(iii). Accordingly grant of sanction is liable to be declared as nullity and invalid and resultantly, impugned

Vipendra Ravindra Mandal, Thane vs. Income Tax Officer- Ward 22(3)(6), Mumbai

In the result, the appeal of the assessee is allowed

ITA 1819/MUM/2025[2016-2017]Status: DisposedITAT Mumbai22 Sept 2025AY 2016-2017

Bench: Shri Om Prakash Kant () & Shri Raj Kumar Chauhan () Assessment Year: 2016-17 Vipendra Ravindra Mandal, Ito Ward 22(3)(6), 405, Orchid Wing-F Lodha Crown, Piramal Chamber, Taloja Bypass Road, Kohni B.O. Vs. Mumbai-400012. Khoni, Thane-421204. Pan No. Alepm 8472 H Appellant Respondent

For Appellant: Mr. V.P. KothariFor Respondent: Mr. Bhagirath Ramawat, Sr. DR
Section 148Section 148ASection 149(1)(A)Section 54

beyond a period of issuance of notice under Section 148 of the Act beyond a period of three years in terms of Section 149(1)(b). Reliance was placed on three years in terms of Section 149(1)(b). Reliance was placed on three years in terms of Section 149 ... beyond the limitation prescribed under Section 148 was issued beyond the limitation prescribed under Section 148 was issued beyond the limitation prescribed under Section 149(1)(b) of the Act. For ease of reference, the under Section 149(1)(b) of the Act. For ease of reference, the under Section

Basudeo Soni, New Delhi vs. ITO Ward 35(1), New Delhi

Appeal is allowed in above terms

ITA 4894/DEL/2025[2016-17]Status: DisposedITAT Delhi22 Sept 2025AY 2016-17

Bench: Sh. Satbeer Singh Godaraita No. 4894/Del/2025 : Asstt. Year : 2016-17 Basudeo Soni, Vs Income Tax Officer, C/O B-50, Lgf, South Extension-Ii, Ward-35(1), New Delhi-110049 New Delhi (Appellant) (Respondent) Pan No. Agyps4983N Assessee By: Sh. Saantanu Jain, Adv. & Ms. Jahanvi Khanna, Adv. Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 22.09.2025 Date Of Pronouncement: 22.09.2025

For Appellant: Sh. Saantanu Jain, Adv. &For Respondent: Sh. Manoj Kumar, Sr. DR
Section 13ASection 147Section 148Section 148ASection 29A

filed by the petitioner. Since the said period was less than seven days, the AO had, by virtue of the fourth proviso to Section 149(1) of the Act, seven days to pass an order under Section 148A(d) of the Act (which was necessarily required to accompany a notice

Seema Goel, Delhi vs. CIT A, Delhi

The appeals of the assessee are allowed

ITA 2006/DEL/2025[2016-17]Status: DisposedITAT Delhi22 Sept 2025AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 144Section 147Section 148Section 148ASection 14tSection 250Section 271Section 69A

TOLA applies to the entire Income Tax Act, Including Sections 149 and 151 of the new regime. Once the first proviso to Section 149(1)(b) is read with TOLA, then all the notices issued between 1 April 2021 and 30 June 2021 pertaining to assessment years ... Agarwal (supra), this Court allowed the assesses to avail all the defences, including the defence of expiry of the time limit specified under Section 149(1). In the instant appeals, the reassessment notices pertain to the assessment years

Seema Goel, Delhi vs. CIT A, Delhi

The appeals of the assessee are allowed

ITA 2005/DEL/2025[2015-16]Status: DisposedITAT Delhi22 Sept 2025AY 2015-16

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 144Section 147Section 148Section 148ASection 14tSection 250Section 271Section 69A

TOLA applies to the entire Income Tax Act, Including Sections 149 and 151 of the new regime. Once the first proviso to Section 149(1)(b) is read with TOLA, then all the notices issued between 1 April 2021 and 30 June 2021 pertaining to assessment years ... Agarwal (supra), this Court allowed the assesses to avail all the defences, including the defence of expiry of the time limit specified under Section 149(1). In the instant appeals, the reassessment notices pertain to the assessment years

Manda Shantaram Garade, Talegaon Dabhade vs. Income Tax Officer 9(3), Akurdi

In the result, appeal of the assessee is allowed for statistical purpose

ITA 1343/PUN/2025[2019-20]Status: DisposedITAT Pune19 Sept 2025AY 2019-20

Bench: Ms.Astha Chandra & Dr.Dipak P. Ripoteआयकर अपऩल सं. / Ita No.1343/Pun/2025 निर्धारण वषा / Assessment Year: 2019-20 Manda Shantaram Garade, V The Assessing Officer, 66, Dhamane Gavthan, Near S Ward-9(3), Pune. Padmavati Mandir, Talegaon, Maharashtra – 410506. Pan: Bjcpg4762K Appellant/ Assessee Respondent / Revenue Assessee By Shri Nishit Gandhi(Virtual), Aadnya Bhandari(Present In Itat Pune Bench) Revenue By Shri Ramnath P Murkunde – Cit(Dr) Date Of Hearing 18/09/2025 Date Of Pronouncement 19/09/2025 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Filed By The Assessee Against The Order Of Ld.Commissioner Of Income Tax(Appeal)[Nfac] Passed Under Section 250 Of The Income Tax Act, 1961 Dated 26.03.2025 For The A.Y.2019-20 Emanating From The Assessment Order Passed Under Section 147 R.W.S 144 Read With Section 144B Of The Income Tax Act

Section 144Section 144BSection 147Section 148ASection 149(1)Section 151ASection 250Section 69A

Rs.94,28,953 are made by the Ld. AO to validate his actions so as to get over the limitation contained in section 149(1) of the Act. ITA No.1343/PUN/2025 [A] 1.3 In the facts and circumstances of the case and in law, the impugned re-assessment be quashed

Megnanapuram Paccs, Tiruchendur vs. PCIT, Madurai

ITA 895/CHNY/2025[2018-19]Status: DisposedITAT Chennai19 Sept 2025AY 2018-19

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita No.:895/Chny/2025 निर्धारण वर्ष / Assessment Year: 2018-19 Megnanapuram Primary Agricultural Co-Operative Credit Society 4/40, Megnanapuram Tiruchendur Road, Tiruchendur Thoothukudi – 628 210. [Pan: Aabam-9847-M] (अपीलार्थी/Appellant) Pcit Vs. Madurai - I (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By : Shri. N. Arjun Raj, Advocate प्रत्यर्थी की ओर से/Respondent By : Shri. Shiva Srinivas, Cit सुनवाई की तारीख/Date Of Hearing : 24.06.2025 घोषणा की तारीख/Date Of Pronouncement : 19.09.2025 आदेश /Order Per S. R. Raghunatha, Am : This Appeal By The Assessee Is Filed Against The Order Of The Commissioner Of Income Tax (Appeals), Pcit, Madurai - 1, For The Assessment Year 2018-19, Vide Order Dated 17.03.2025. 2. The Grounds Raised By The Assessee Are As Follows: :-2-:

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Shri. Shiva Srinivas, CIT
Section 147Section 148Section 263Section 80P

आयकर अपीलीय अधिकरण, 'बी' न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL 'B' BENCH, CHENNAI श्री मनु कुमार गिरि, न्यायिक

Musaddilal Mansaram Infrastructure Pvt. Ltd., Bilaspur vs. Income Tax Officer, Ward-1(1), Bilaspur

The appeal of the assessee is allowed, whereas the appeal of revenue stands dismissed

ITA 160/RPR/2025[2015-16]Status: DisposedITAT Raipur18 Sept 2025AY 2015-16

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 160/Rpr/2025 (िनधा"रण वष" Assessment Year: 2015-16)

For Appellant: Shri Veekaas S Sharma, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 143(2)Section 143(3)Section 147Section 148Section 149Section 149(1)(a)Section 151Section 153CSection 50C(2)Section 56(2)(vii)

assessment proceedings initiated via notice u/s 148 dated 31.03.2021 but issued only on 01.04.2021 is barred by limitation under the amended Section 149(1)(a), as the alleged escaped income is only Rs. 30,00,000 which is below the threshold of Rs. 50,00,000. The limitation us/ 149

Income Tax Officer-1(1), Bilaspur vs. Musaddilal Mansaram Infrastructure Pvt. Ltd., Bilaspur

The appeal of the assessee is allowed, whereas the appeal of revenue stands dismissed

ITA 153/RPR/2025[2015-16]Status: DisposedITAT Raipur18 Sept 2025AY 2015-16

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Arun Khodpia, Am आयकर अपील सं. / Ita No: 160/Rpr/2025 (िनधा"रण वष" Assessment Year: 2015-16)

For Appellant: Shri Veekaas S Sharma, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 143(2)Section 143(3)Section 147Section 148Section 149Section 149(1)(a)Section 151Section 153CSection 50C(2)Section 56(2)(vii)

assessment proceedings initiated via notice u/s 148 dated 31.03.2021 but issued only on 01.04.2021 is barred by limitation under the amended Section 149(1)(a), as the alleged escaped income is only Rs. 30,00,000 which is below the threshold of Rs. 50,00,000. The limitation us/ 149

Sanjay Kumar Bhutra, Kolkata vs. ITO, Ward 44(2), Kolkata

In the result, all the appeals of the Revenue are dismissed

ITA 261/KOL/2025[2013-14]Status: DisposedITAT Kolkata18 Sept 2025AY 2013-14

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2013-14 Sanjay Kumar Bhutra………...……………………….……….……….……Appellant Geeta Katra, 1, Mullick St., 1St Floor, Burrabazar, Kol- 7.. [Pan: Ahspb7216J] Vs. Ito, Ward-44(2), Kolkata………………………………….....……...…..…..Respondent Appearances By: Shri S. K. Pransukha, Appeared On Behalf Of The Appellant. Shri S. B. Chakraborthy, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 04, 2025 Date Of Pronouncing The Order : September 18, 2025 Order Per Pradip Kumar Choubey: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 19.12.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As The “Ld. Cit(A)”] Passed U/S 250 Of The Income Tax Act, 1961 [Hereinafter Referred To As The “Act”].

Section 148Section 148ASection 149Section 250Section 3(1)

TOLA applies to the entire Income Tax Act including Sections 149 and 151 of the new regime. Once the first proviso to Section 149(1)(b) is read with TOLA, then all the notices issued between 1 April 2021 and 30 June 2021 pertaining to assessment years ... Supreme Court has explained the extension of TOLA time limit till 31/06/2021 in the following manner:- "54. The proviso to Section 149(1)(b) of the new regime uses the expression "beyond the time limit specified under the provisions of clause (b) of sub- section (1) of this section

M/S Vibhuti Marketing Pvt. Ltd., Kolkata vs. ITO, Ward-11(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 689/KOL/2024[2013-14]Status: DisposedITAT Kolkata12 Sept 2025AY 2013-14

Bench: the Assessing Officer by stating that the assessee received Rs.10,00,000/- from M/s Gajgamini Commodities on account of sale of shares. However, the Assessing Officer without doing any verification on the evidences furnished by the assessee which comprises of ledger account, bank statement, ITR, Balance Sheet etc. of Gajgamini Commodities Pvt. Ltd. The ld AO came to the conclusion that the assessee has not prove the genuineness of the transaction and consequently added amount to the income

Section 147Section 148Section 148ASection 250

case, has been issued after three years from the end of the relevant assessment year, as required under the provisions of section 149(1)(b) of the Act, constitutes a jurisdictional error on the part of the respondents. 11. Learned counsel for the petitioner makes a reference to a Division

Millennium Contrade Pvt. Ltd., Kolkata vs. DCIT, Circle- 11(1), Kolkata

In the result, the appeal filed by the assessee is partly allowed for

ITA 424/KOL/2025[2014-15]Status: DisposedITAT Kolkata11 Sept 2025AY 2014-15

Bench: Shri George Mathan

Section 143(3)Section 147Section 148Section 149(1)(b)Section 68Section 69C

facts and in circumstances of the case and in law, reassessment proceedings initiated by the AO are in contravention to the provisions of Section 149(1)(b) of the Act. The issue of Notice U/s 148 for AY 2014-15 is barred by limitation and hence reassessment proceedings