During the search proceedings of Mr. Meet, the AO find out that the income of Mr. Meet for the AY 2020-21 has escaped assessment to the tune of ₹ 50 Lakhs. The AO send the notice u/s 148 to the Mr. Meet on 14th June 2026

As per the provision of section 149 of the Income tax Act, 1961, the time limit for issue of notice u/s 148 for the amount involved equal to or more than 50 lakh is up to 5 years and 3 months from the end of the relevant assessment year. Further the specified authority for the purposes of section 148 and 148A shall be the Additional Commissioner or the Additional Director or the Joint Commissioner or the Joint Director, as the case may be w.e.f. 01.09.2024. In the given case, as the amount involved is equal to ₹ 50 Lakh, the notice can be issued till 30.06.2026 i.e., up to 5 years and 3 months from the end of the relevant assessment year. As the Notice is issued on 14th June 2026, the Notice is not time barred and accordingly contention of Mr. Meet is not correct. However, the notice is issued by the AO himself, who is not the specified authority under the Act. Therefore, the contention of Mr. Meet is correct with regard to non-approval of competent authority.