Held that Section 148A(b) of the Income-tax Act, 1961, requires providing opportunity of being heard to the assessee by serving upon him or her a notice to show cause within such time as may be specified in the notice being “not less than seven days” but not exceeding thirty days from the date on which such notice is issued. Both the terminal days have to be excluded for the purpose of complying with the requirement of words “not less than… days”. Held,  that admittedly, the notice dated March 16, 2022 was issued or posted on March 17, 2022 and the date fixed for response was March 23, 2022. Excluding the date of sending of the notice as well the last date indicated, even if the notice was received by the assessee, the time granted fell short of the seven day period, as envisaged by the provisions of section 148A(b) of the Act; and, for violation of mandatory provisions of section 148A(b) of the Act, the notice issued to the assessee could not be sustained. Court also held that moreover, the amount was less than Rs. 50,00,000 and for the assessment year 2015-2016, the notice had been issued on March 16, 2022, i.e. beyond three years. It was ex facie barred by limitation and consequently was without jurisdiction.(AY. 2015-16)