Held that notice under section 148 can be issued by Assessing Officer even if time-limit for issuance of notice under section 143(2) has not expired in pursuance of return filed under section 139 for completing regular assessment under section 143(3). Assessing Officer only has to show that there is a case of under assessment as mentioned in either of three clauses to Explanation 2 to section 147. Clause (b) to Explanation 2 clearly provides that where assessment is not completed, still there could be a case of deemed escapement of income and notice under section 148(1) can be issued irrespective of fact whether assessment proceedings initiated by virtue of filing return or assessment proceedings by way of issuance of notice under section 143(2) are concluded or not. Period of notice shall be counted from relevant assessment year for limitation of issuing notice under section 148 which period also covers period of notice to be issued as per section 143(2).  (AY. 2012-13)