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B. any audit objection to the effect that the not apply in cases where the Assessing Officer has
assessment in the case of the assessee for the received any information under the scheme notified
relevant assessment year has not been made in under section 135A, pertaining to income
accordance with the provisions of this Act; or chargeable to tax escaping assessment for any

C. any information received under an agreement assessment year in the case of the assessee.
5. The Finance Act 2022 inserted new Section 148B:
referred to in section 90 or section 90A of the Act; or
Prior Approval For Assessment, Reassessment Or
D. any information made available to the Assessing Recomputation in Certain Cases:
Officer under the scheme notified under section
135A; or It has brought new section which provides that no
order of assessment or reassessment or
E. any information which requires action in
recomputation under the Act shall be passed by an
consequence of the order of a tribunal or a court. Assessing Officer below the rank of Joint
It has amended clause (ii) of Explanation 2 of the said
Commissioner, except with the prior approval of the
section to omit the reference of sub-section (5) of
Additional Commissioner or Additional Director or
section 133A.
Joint Commissioner or Joint Director, in respect of an
It has also amended Explanation 2 to the said section assessment year to which clause (I), clause (ii),
to provide that the Assessing Officer shall be clause (iii) or clause (iv) of the Explanation 2 to
deemed to have information which suggests that section 148 apply.
the income chargeable to tax has escaped 6. The Finance Act 2022 amended Section 149:
assessment in the case of
Time limit for notice :
the assessee where the
The said section 149
search is initiated or books provides the time limit for
o f a c c o u n t , o t h e r
issuance of notice under
documents or any assets s e c t i o n 1 4 8 f o r
are requisitioned or
assessment, reassessment
survey is conducted in the
or recomputation of
case of the assessee or income.
money, bullion, jewellery
The Finance Act 2022
or other valuable article or
amended the clause (b) of
thing or books of account or documents are seized sub-section (1) of the section 149 to provide that no
or requisitioned in case of any other person.
notice under section 148 shall be issued for the
These amendments except for amendment in relevant assessment year after three years but prior
Explanation 2 is effective from 1st April, 2022. The to ten years from the end of the relevant assessment
amendment in Explanation 2 is effective from 1st year unless the Assessing Officer has in his
April, 2021. possession books of account or other documents or
4. The Finance Act 2022 further amended section evidence which reveal that the income chargeable
148A: Conducting inquiry, providing opportunity to tax, represented in the form of :
before issue of notice under Section 148 : A. an asset; or
The earlier Clause (b) of the section 148A provided B. expenditure in respect of a transaction or in
that an opportunity of being heard shall be provided relation to an event or occasion; or
to the assessee, with prior approval of specified C. an entry or entries in the books of account, which
authority. It has omitted the requirement of has escaped assessment amounts to or likely to
approval of specified authority in clause (b). The amount to fifty lakh rupees or more.
new clause (d) in the proviso to the said section It further brought a new sub-section (1A) in the
provide that the provisions of the said section shall
section 149 to provide that notwithstanding

29 Life is ten percent what happens to you and ninety percent how you respond to it.