“Section 149(1)(b)”

Section References (mined)Section 149Section 149(1)(b)664 judgments

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

Leading authorities on Section 149(1)(b)

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.

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.

7.14 In CIT v. Gwalior Rayon Silk Mfg. Co. Ltd.

196 ITR 149 · 1992 · Supreme Court

120

citing judgments

Incentive provisions in the Income-tax Act, particularly those granting deductions for new industrial undertakings, must be construed liberally to achieve their legislative purpose. This principle guides the interpretation of conditions such as what constitutes a 'new undertaking' versus a 'splitting up or reconstruction' of an existing business for claiming deductions.

Deepak Steel and Power Ltd. v. Central Board of Direct Taxes

174 Taxmann.com 144 · 2025 · Supreme Court

citing judgments

Reassessment notices issued after April 1, 2021, for Assessment Year 2015-16 are time-barred. The relaxation provided by the Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, does not extend the period of limitation for such notices.

Ravi Badalia v. DCIT

158 Taxmann.com 373 · Reported

citing judgments

Additions made in respect of credits reflected in foreign bank accounts for unabated assessment years must be based on incriminating material found during the search.

M B Traders v. ACIT

132 TTJ 490 · 2010 · ITAT

citing judgments

Section 148 notices can be issued at any time for assessments or reassessments made in consequence of or to give effect to any final finding, direction, or order of any higher authority.

B.K Gooyee v. CIT

62 ITR 109 · 1966 · High Court

citing judgments

A notice issued under section 34 of the Income-tax Act, 1922, that is not signed by the Income Tax Officer is invalid and considered no notice at all, as the signature is an essential and integral part of the notice.

P. Satyanarayana Chetty v. Income Tax Officer

101 ITR 385 · 1975 · High Court

citing judgments

Sanction for reassessment proceedings under Section 151 of the Income Tax Act must be granted with due application of mind and cannot be a mechanical or routine exercise.

Judgments citing Section 149(1)(b)

Vertex Buildwell Private Limited, Delhi vs. Income Tax Officer, Ward - 26(2), C R Building, New Delhi

In the result, appeal of assessee in ITA No

ITA 2064/DEL/2025[2012-13]Status: DisposedITAT Delhi30 Oct 2025AY 2012-13

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri Satyajeet Goyal, CAFor Respondent: Shri Manish Gupta, Sr. DR

Section 131Section 133(6)Section 143(3)Section 147

such initiation may not be time-barred keeping in view only the provisions of section 149(1). In other words, the provisions of section 149(1)(b) enacting provisions as to extended period of limitation can be invoked only in cases falling outside the ambit of the proviso to section

DCIT, Circle - 10(1), Delhi vs. Interlink Foods Private Limited, South Delhi

Accordingly, the cross objections for AY 2016-17 filed by the assessee is allowed

ITA 4671/DEL/2024[2016-17]Status: DisposedITAT Delhi29 Oct 2025AY 2016-17

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Gurdev Singh Chawla, AdvocateFor Respondent: Shri Om Prakash, Sr. DR

Section 143(1)Section 148

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 Taxation and other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, then all the notices issued between April 1

DCIT, Circle - 10(1), New Delhi vs. Interlink Foods Private Limited, South Delhi

Accordingly, the cross objections for AY 2016-17 filed by the assessee is allowed

ITA 4670/DEL/2024[2015-16]Status: DisposedITAT Delhi29 Oct 2025AY 2015-16

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Gurdev Singh Chawla, AdvocateFor Respondent: Shri Om Prakash, Sr. DR

Section 143(1)Section 148

DCIT, Circle - 10(1), Delhi vs. Interlink Foods Private Limited, South Delhi

Accordingly, the cross objections for AY 2016-17 filed by the assessee is allowed

ITA 4669/DEL/2024[2011-12]Status: DisposedITAT Delhi29 Oct 2025AY 2011-12

Bench: Shris.Rifaur Rahman & Shri Yogesh Kumar U.S.

For Appellant: Shri Gurdev Singh Chawla, AdvocateFor Respondent: Shri Om Prakash, Sr. DR

Section 143(1)Section 148

Anupama Vintrade Private Limited, Kolkata vs. ITO, Ward 10(2), Kolkata

In the result, the appeal filed by the assessee is allowed and the appeal of Revenue is dismissed

ITA 1313/KOL/2025[2015-16]Status: DisposedITAT Kolkata27 Oct 2025AY 2015-16

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2015-16 Anupama Vintrade Pvt. Ltd..….……………………….……….……….……Appellant 77, 4Th Floor, Room 422, Elliot Road, Kol-700016.. [Pan: Aahca5675R] Vs. Ito, Ward-10(2), Kolkata….……………………………….....……...…..…..Respondent Appearances By: Shri Somnath Ghosh, Advocate, Appeared On Behalf Of The Appellant. Shri Manas Mondal, Addl. Cit-Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 16, 2025 Date Of Pronouncing The Order : October 27, 2025 Order Per Pradip Kumar Choubey: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 08.03.2025 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). The Appeal Has Been Filed By The Assessee With A Delay Of 14 Days. 2. The Assessee Has Filed An Affidavit For Condonation Of The Delay. After Considering The Reasons Cited In The Affidavit For Condonation Of Delay, We Find That The Reasons Are Valid & Consequently, The Delay In Filing The Appeal Is Hereby Condoned & We Proceed To Dispose Of The Appeal On Merits.

Section 133(6)Section 143(1)Section 147Section 148Section 148ASection 149(1)(b)Section 250

conceded on behalf of the Revenue that all notices issued under the new regime by invoking the six year time limit prescribed under section 149(1)(b) of the old regime will have to be dropped if the income chargeable to tax which has escaped assessment is less than Rupees

ITO, Ward 10(2), Kolkata vs. Alex Tradecom Private Limited, Kolkata

In the result, the appeal of the assessee is allowed

ITA 2198/KOL/2024[2014-15]Status: DisposedITAT Kolkata27 Oct 2025AY 2014-15

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.2197 & 2198/Kol/2024 Assessment Years: 2013-14 & 2014-15 Ito, Ward-10(2), Kolkata…………..…………………………….…….……Appellant Vs. Alex Tradecom Pvt. Ltd…………..……………….………...……...…..…..Respondent 4, Ratan Sarkar Garden Street, Burrabazar, Kol- 700069. [Pan: Aajca6146P] Appearances By: Smt. Madhumita Das, Addl. Cit, Sr. Dr, Appeared On Behalf Of The Appellant. Shri Akshay Ringasia, Ca, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 15, 2025 Date Of Pronouncing The Order : October 27, 2025 Order Per Pradip Kumar Choubey: Both The Captioned Appeals Have Been Preferred By The Revenue For The Assessment Years 2013-14 & 2014-15 Against Separate Orders Dated 05.08.2024 & 26.07.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In Both The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. 2. Both The Appeals Have Been Filed By The Revenue With Delays Of 38 Days. The Revenue Has Filed Separate Affidavits For Condonation Of The Delays. After Considering The Reasons Cited In The Affidavits For Condonation Of Delay, We Find That The Reasons Are Valid And

Section 148Section 148ASection 250

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

ITO, Ward-10(2), Kolkata vs. Alex Tradecom Private Limited, Kolkata

In the result, the appeal of the assessee is allowed

ITA 2197/KOL/2024[2013-14]Status: DisposedITAT Kolkata27 Oct 2025AY 2013-14

Section 148Section 148ASection 250

Deputy Commissioner of Income Tax, Central Circle-15, Delhi vs. Divyansh Infracon Private Limited, Delhi

In the result, the appeals of the Revenue in ITA Nos

ITA 543/DEL/2025[2012-13]Status: DisposedITAT Delhi27 Oct 2025AY 2012-13

Bench: Shri Yogesh Kumar U.S. & Shri Naveen Chandra

For Appellant: Shri V.K. Sabharwal, AdvFor Respondent: Ms. Pooja Swaroop, CIT- DR

Section 148Section 149Section 153ASection 153C

well as AY 2012- 13 in the instant case, is beyond the period of ten assessment years as prescribed under the provisions of section 149(1)(b) and is therefore barred by limitation. Our view is fortified by the decision of the Hon'ble Supreme Court in the case

Deputy Commissioner of Income Tax, Central Circle-15, Delhi vs. Divyansh Infracon Private Limited, Delhi

In the result, the appeals of the Revenue in ITA Nos

ITA 538/DEL/2025[2013-14]Status: DisposedITAT Delhi27 Oct 2025AY 2013-14

Bench: Shri Yogesh Kumar U.S. & Shri Naveen Chandra

For Appellant: Shri V.K. Sabharwal, AdvFor Respondent: Ms. Pooja Swaroop, CIT- DR

Section 148Section 149Section 153ASection 153C

Gaurav Tiwari, Uttar Pradesh vs. DCIT, Circle 1(1), Gurugram

In the result, appeal of the assessee is allowed

ITA 1695/DEL/2025[2015-16]Status: DisposedITAT Delhi27 Oct 2025AY 2015-16

Bench: Shri Vikas Awasthyआअसं.1695/िद"ी/2025 (िन.व. 2015-16) Gaurav Tiwari, 1401, Tower-6, Unitech Horizon, ...... अपीलाथ"/Appellant Sector-Pi, Greater Noida, Uttar Pradesh 201301 Pan: Aezpt-4925-L बनाम Vs. Deputy Commissioner Of Income, ..... "ितवादी/Respondent Circle 1(1), Gurugram, Haryana 122016 अपीलाथ" "ारा/Appellant By : S/Shri Ajay Goyal & Mudit Dewan, Advocates "ितवादी"ारा/Respondent By : Ms. Sudha Gupta, Sr.Dr सुनवाई क" ितिथ/ Date Of Hearing : 30/07/2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 27/10/2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [In Short ‘The Cit(A)’] Dated 15.01.2025, For Assessment Year 2015-16. 2. Shri Ajay Goyal, Appearing On Behalf Of The Assessee Submits That The Assessment For Ay 2015-16 Was Reopened For The Reason:- (I) The Assessee Had Purchased Immovable Property Worth Rs.55,04,000/- During Financial Year 2014-15;

For Appellant: S/Shri Ajay Goyal & Mudit Dewan, AdvocatesFor Respondent: Ms. Sudha Gupta, Sr.DR

Section 147Section 148Section 148ASection 149Section 149(1)Section 149(1)(b)Section 56(2)(vii)

merely Rs.22,72,444/-. The escaped assessment amount is for less than Rs.50,00,000/-. Therefore, in light of 4 provision of section 149(1)(b) of the Act, the assessment is without jurisdiction, hence, liable to be quashed. I hold accordingly. 7. In the result, appeal of the assessee

Dineshbhai Mulachandabhai Patel, Surat vs. ITO, Ward 2(3)(1), Surat

In the result, the appeal of the assessee is allowed

ITA 1371/SRT/2024[2013-14]Status: DisposedITAT Surat17 Oct 2025AY 2013-14

Bench: Shri Dinesh Mohan Sinha & Shri Bijayananda Prusethआयकर अपील सं./Ita No.1371/Srt/2024 Assessment Year: 2013-14 (Hybrid Hearing) Dineshbhai Mulachandabhai Income Tax Officer Ward-2(3)(1), बनाम/ Patel Surat, Aaykar Bhawan, Majura Vs. Patidar Faliyu, Bhestan Gam, Gate, Surat-395 001 Choryasi, Surat- 395 023 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Bispp 4863 K (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant By Shri P.M. Jagasheth, Ca राज" की ओर से /Respondent By Shri Ajay Uke, Sr-Dr सुनवाई की तारीख/Date Of Hearing 29/07/2025 उद्घोषणा की तारीख/Date Of Pronouncement 17/10/2025

Section 142(1)Section 144Section 147Section 148Section 149(1)Section 250Section 271(1)(c)Section 50C

escaped assessment was below threshold limit of Rs. 50 ITA No.1371/Srt/2024 A.Y 13-14 Dineshbhai M Patel lakhs for attracting provision of section 149(1)(b), impugned notice having been issued beyond period of limitation as prescribed u/s 149(1)(a), same was to be set aside. 7.1 In view

M.A. Financial Services Pvt. Ltd., Kolkata vs. ITO, Ward 4(1), Kolkata

In the result, the appeal filed by the assessee is allowed and the appeal of Revenue is dismissed

ITA 1272/KOL/2025[2015-2016]Status: DisposedITAT Kolkata17 Oct 2025AY 2015-2016

Bench: Shri Pradip Kumar Choubey & Shri Sanjay Awasthiassessment Year: 2015-16 M. A Financial Services Pvt. Ltd.……………………….……….……….……Appellant 2, Lal Bazaar Street, 1St Floor, Kol-700001.. [Pan: Aaccm0481E] Vs. Ito, Ward-4(1), Kolkata…….…………………………….....……...…..…..Respondent Appearances By: Shri Manoj Kataruka, Ar, Appeared On Behalf Of The Appellant. Shri Praveen Kishore, Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : October 09, 2025 Date Of Pronouncing The Order : October 17, 2025 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 16.05.2025 Of The National Faceless Appeal Centre [‘Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2015–16. 2. Brief Facts Of The Case Of The Assessee Are That The Assessee Filed Its Return Of Income For The A.Y 2015-16 U/S 139 Of The Act On 20.07.2015 Declaring Total Income Of Rs.9,647/-. The Said Return Was Processed U/S 143(1) Of The Act. Later On, Based On Information Received Through Itba Software Under The Head High Risk Transaction Case Notice U/S 148A(B) Of The Act Was Issued & Finally Notice U/S 148 Of The Act Was Issued On 13.07.2022. In Response, The Assessee Filed Return On 02.11.2021 Declaring Total Income Of Rs.9,647. Assessment Was Made Under Sec. 147 M. A Financial Services Pvt. Ltd Read With Section 144B Of The Act On 24.05.2023 Determining Total Income Of Rs.6,55,31,471/- Inter-Alia Making Following Addition:

Section 139Section 143(1)Section 144BSection 147Section 148Section 148ASection 149(1)(b)Section 250Section 69A

Deepak Agarwal, Delhi vs. DCIT, Central Circle- 25, Delhi

ITA 2309/DEL/2025[2021-22]Status: DisposedITAT Delhi15 Oct 2025AY 2021-22

Bench: Shri S Rifaur Rahman, Accountnat Member & Shri Anubhav Sharma

Section 1Section 139(1)Section 143(3)Section 147Section 148Section 148(2)Section 151Section 153ASection 68

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘A’: NEW DELHI BEFORE SHRI S RIFAUR RAHMAN, ACCOUNTNAT MEMBER AND SHRI

Deepak Agarwal, Delhi vs. DCIT, Central Circle- 13, Delhi

ITA 2308/DEL/2025[2018-19]Status: DisposedITAT Delhi15 Oct 2025AY 2018-19

Bench: Shri S Rifaur Rahman, Accountnat Member & Shri Anubhav Sharma

Section 1Section 139(1)Section 143(3)Section 147Section 148Section 148(2)Section 151Section 153ASection 68

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘A’: NEW DELHI BEFORE SHRI S RIFAUR RAHMAN, ACCOUNTNAT MEMBER AND SHRI

Deepak Agarwal, Delhi vs. DCIT, Central Circle-25, Delhi

ITA 2306/DEL/2025[2014-15]Status: DisposedITAT Delhi15 Oct 2025AY 2014-15

Bench: Shri S Rifaur Rahman, Accountnat Member & Shri Anubhav Sharma

Section 1Section 139(1)Section 143(3)Section 147Section 148Section 148(2)Section 151Section 153ASection 68

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘A’: NEW DELHI BEFORE SHRI S RIFAUR RAHMAN, ACCOUNTNAT MEMBER AND SHRI

Deepak Agarwal, Delhi vs. DCIT, Central Circle- 25, Delhi

ITA 2305/DEL/2025[2013-14]Status: DisposedITAT Delhi15 Oct 2025AY 2013-14

Bench: Shri S Rifaur Rahman, Accountnat Member & Shri Anubhav Sharma

Section 1Section 139(1)Section 143(3)Section 147Section 148Section 148(2)Section 151Section 153ASection 68

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH, ‘A’: NEW DELHI BEFORE SHRI S RIFAUR RAHMAN, ACCOUNTNAT MEMBER AND SHRI

Dharampal Satyapal Ltd., New Delhi vs. ACIT Central Circle 29, New Delhi

ITA 5519/DEL/2024[2015-16]Status: DisposedITAT Delhi15 Oct 2025AY 2015-16

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year : 2015-16 Dharampal Satyapal Ltd., Vs. Acit, 98, Okhla Industrial Estate Central Circle-29, Phase Iii, New Delhi. Tehkhand, New Delhi – 110 020. Pan: Aaacd0132H (Appellant) (Respondent) Assessee By : Shri R.S. Singhvi; Shri Satya Jeet Goel; & Shri Rajat Garg, Cas Revenue By : Shri Amit Jain, Cit-Dr Date Of Hearing : 11.09.2025 Date Of Pronouncement : 15.10.2025 Order

For Appellant: Shri R.S. SinghviFor Respondent: Shri Amit Jain, CIT-DR

Section 115JSection 144CSection 147Section 148Section 148ASection 149Section 69ASection 80ISection 92C

through the web of this sham transaction. The case of the appellant is well covered within the purview of Section 149(1)(b) of the Income-tax Act, 1961. In light of information available on record and the submission made by the appellant , the undersigned is satisfied that

Walmark Garment Compamy Pvt Ltd, Mumbai vs. ITO Ward 14(3)(1), Mumbai

In the result, the assessee’s appeal is hereby dismissed

ITA 6979/MUM/2024[2014-15]Status: DisposedITAT Mumbai14 Oct 2025AY 2014-15

Bench: Shri Pawan Singh & Smt.Renu Jauhriwalmark Garment Company Vs. Income Tax Officer Pvt. Ltd. Ward 14(3)(1), Ch. No. 9 , Shop No. 18, Aayakar Bhavan, Porbandarwala Chawl, Mumbai-400020. Chiragnagar, L.B.S Marg, Ghatkopar West, Mumbai-400086. "थायी लेखा सं./जीआइआर सं./Pan/Gir No:Aaacw9438P Appellant .. Respondent

For Appellant: Shri Sharwan Kumar JhaFor Respondent: Shri Swapnil Choudhary- Sr. AR

Section 148Section 148ASection 250Section 69C

IN THE INCOME-TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER & SMT.RENU JAUHRI, ACCOUNTANT MEMBER Walmark

Mudunuri Venkata Subbaraju, West Godavari vs. Income Tax Officer, Ward-1, Tanuku

In the result, appeal of the assessee is allowed

ITA 284/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam13 Oct 2025AY 2015-16

Bench: Shri Ravish Sood, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपीलसं./I.T.A.No.284/Viz/2025 (निर्धारण वर्ा/ Assessment Year: 2015-16) Mudunuri Venkata Subbaraju V. Income Tax Officer – Ward – 1 5-205/2, Dommeru Aayakar Bhavan, 35-29-2 Near Reliance Tower Sajjapuram, Tanuku – 534211 Gowthaminagar S.O. Andhra Pradesh Kovvur, West Godavari – 534350 Andhra Pradesh [Pan:Cupps3676D] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) करदाता का प्रतततितित्व/ Assessee Represented By : Shri C. Subrahmanyam, Ca राजस्व का प्रतततितित्व/ Department Represented By : Dr.Aparnavilluri, Sr.Ar

Section 143(2)Section 147Section 148ASection 250Section 69A

1. The notice issued u/s 148 of the IT Act, 1961 dt. 06.04.2022 is barred by limitation in view of the provisions of section 149(1)(b) of the IT Act, 1961 read with the proviso thereto. Since the notice was issued beyond the prescribed time limit of six years ... Ld.AR also submitted that notice under section 148 of the Act dated 06.04.2022is barred by limitation as per the first proviso to section 149(1)(b) of the Act w.e.f 01.04.2021. Ld.AR pleaded that Page. No 4 I.T.A.No.284/VIZ/2025 Mudunuri Venkata Subbaraju the legal ground raised by the assessee

Ananda Aqua Exports, Ganapavaram vs. Income Tax Officer, Ward-1, Bhimavarm

ITA 15/VIZ/2025[2017-18]Status: DisposedITAT Visakhapatnam13 Oct 2025AY 2017-18

Section 143(3)Section 148Section 148ASection 149(1)(b)Section 250Section 250(6)Section 69Section 69A

than the threshold limit of Rs.50 lacs, therefore, it impacts the determination of income escaping assessment and theapplicability of statutory provisions such as Section 149(1)(b) of the Income Tax Act, 1961. Page. No 3 7. The Ld. CIT(A) ought to have taken into cognizance that the proceedings ... 1. The notice issued u/s 148 of the IT Act, 1961 dt. 26.07.2022 is barred by limitation in view of the provisions of section 149(1)(b) of the IT Act, 1961 read with the proviso thereto. Since the notice was issued beyond the prescribed time limit of three years