Assessee challenged notice issued under section 148-It was noted that the period of six years for the relevant assessment year 2016-17 expired on 31-3-2022. High Court held that since notice had been issued thereafter on 30-8-2024, the same was barred by limitation. SLP of revenue was dismissed on account of delay of 411 days and also on merits. (AY. 2016-17)