Dismissing the appeal of the assessee the Court held that  the record did not show that the issue of limitation had been raised before the Tribunal on a factual foundation that though notice under section 148 of the Income-tax Act, 1961 bore the date March 31, 2017, it was not issued on that date but it was put in the course of dispatch after that date.  Question of fact. No substantial  question. of law.  SLP of the assessee is dismissed.