In the result, the appeal filed by the assessee is allowed for statistical purpose
Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta
section 149(1)(b) stands violated in this case. In support of his contention, he relied on the following decisions of 5 I.T.A. Nos. 701 & 406/Asr/2024 Assessment Year: 2015-16 various courts and Tribunals to argue that if more than three years have lapsed, then the notice u/s 148 can be issued only if value of income escaping is more