In the result, the appeals of the assessee are partly allowed
Bench: Shri Rajesh Kumar, Am & Shrigeorge Mathan, Jm
68 of the Income-tax Act, 1961 (the Act). 029. In the appellate proceedings, the learned CIT (A) affirmed the order of the learned AO on merit, however, the issue of notice u/s 148 being time barred was not raised and thus, not adjudicated by the learned Commissioner of Income-tax (Appeals). 030. After hearing the rival contentions and perusing