1 (1) No notice under section 148 shall be issued for the relevant assessment year,-
2 (a) if four years have elapsed from the end of the relevant assessment year, unless the case falls under clause (b) 3 or clause (c);
(b) if four years, but not more than six years, have elapsed from the end of the relevant assessment year unless the income chargeable to tax which has escaped assessment amounts to or is likely to amount to one lakh rupees or more for that year;
3 (c) if four years, but not more than sixteen years, have elapsed from the end of the relevant assessment year unless the income in relation to any asset (including financial interest in any entity) located outside India, chargeable to tax, has escaped assessment.
Explanation.-In determining income chargeable to tax which has escaped assessment for the purposes of this sub-section, the provisions of Explanation 2 of section 147 shall apply as they apply for the purposes of that section.
(2) The provisions of sub-section (1) as to the issue of notice shall be subject to the provisions of section 151.
(3) If the person on whom a notice under section 148 is to be served is a person treated as the agent of a non-resident under section 163 and the assessment, reassessment or recomputation to be made in pursuance of the notice is to be made on him as the agent of such non-resident, the notice shall not be issued after the expiry of a period of 4 six years from the end of the relevant assessment year.
5 Explanation.-For the removal of doubts, it is hereby clarified that the
provisions of sub-sections (1) and (3), as amended by the Finance Act, 2012,
shall also be applicable for any assessment year beginning on or before the 1st
day of April, 2012.
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1. Subs. by Act 4 of 1988, s. 55, for sub-section (1) (w.e.f. 1-4-1989).
2. Subs. by Act 14 of 2001, s. 63, for clauses (a) and (b) (w.e.f. 1-6-2001).
3. Ins. by Act 23 of 2012, s. 65 (w.e.f. 1-7-2012).
4. Subs. by Act 23 of 2012, s. 65, for "two years" (w.e.f. 1-7-2012).
5. Ins. by s. 65, ibid. (w.e.f. 1-7-2012).
Section 144 Best judgment assessment
Section 144A Power of Joint Commissioner to issue directions in certain cases
Section 144BA Reference to Principal Commissioner or Commissioner in certain cases
Section 144C Reference to dispute resolution panel
Section 145 Method of accounting
Section 145A Method of accounting in certain cases
Section 147 Income escaping assessment
Section 148 Issue of notice where income has escaped assessment
Section 149 Time limit for notice
Section 150 Provision for cases where assessment is in pursuance of an order on appeal, etc