Notice u/s 148A(b)/Order u/s 148A(d) for issue of notice 148 of the Income Tax Act

gurmukh (prop) (26 Points)

17 April 2023  

I have a question regarding an assessment made under section 147 read with section 144 of the Income Tax Act. Can an assessment be made for the income of Rs. 26 lakh in March 2023 for the assessment year 2015-16, based on a notice and order issued under sections 148A(b) and 148A(d) in March 2022, which had information about a one cash deposit of Rs. 26 lakh reflected both in  AIR-001 and CIB-410. The assessing officer, while issuing the notice and passing the order under sections 148A(b) and 148A(d), considered the amount as Rs. 52 lakh (for one cash deposit of 26 lakh) and deemed it as a case of escaped income chargeable to tax for the year under consideration, warranting the issuance of a notice under section 148.

Whether notice issued u/s 148 in March 2022 for opening the case of  AY 2015-16 is a valid notice?