The amount involved is only Rs. 8 lakhs which was less than Rs. 50 lakhs.  The assessee challenged the notice issued under section 148 of the Act. Allowing the petition the Court held that the Finance Act, 2021 with effect from April 1, 2021, amended section 149 of the Income-tax Act, 1961, which now provides for the time limit within which proceedings under section 148 of the Act could be initiated. Clause (a) of sub-section (1) of section 149 of the Act provides that no notice under section 148 of the Act shall be issued for the relevant assessment year if three years have elapsed from the end of the relevant assessment year, unless the case falls under clause (b)-that is unless the alleged income involved exceeds Rs. 50 lakhs notice under section 148 of the Act cannot be issued.(AY.2016-17)