Bench: Shri Kul Bharatshri Manish Borad
148 could have been issued only within a period of six years from the end of relevant assessment year i.e. AY 2012-13 which, in the present case falls on dated 31.03.2019 and therefore, no further action u/s 147 was permissible. The ld. CIT being conscious of this fact, issued the showcase notice under S. 263 on 23.02.2022, taking altogether