Dismissing the petition the Court held that since the Information available with the Assessing Officer of  the total escaped income was Rs.1,84,45,194, which was more than Rs. 50 Lakhs.   That the notice dated April 5, 2023 issued under Section 148 was not in violation of  the Notification of  the Ministry Of Finance Dated March 29, 2023. Since the initial notice issued under Section 148A(b) had already been issued to the assessee on February 28, 2023. Therefore, the process of  issuing notice under Section 148 had begun prior to the issuance of the Notification. Hence, the notice under Section 148 had not been issued in non-compliance of  the Notification. The Assessee would have the opportunity to represent before the Assessing Officer in response to the notice issued under Section 148. Therefore, the order under Section 148A(d) and the consequent notice under Section 148  is valid.  (AY. 2016-17)