The petitioner challenged the order passed under section 148A(d) of the Act. The notice under Section 148 A(b) dated 23.03. 2022  grants time to the petitioner to respond to the same by 29.03. 2022. The period as granted is less than seven days as prescribed by Section 148A(b) of the Act of 1961.  The petitioner has responded to the notice by his reply dated 29.03. 2022. As regards deposit of cash of Rs.16,20,000/-is concerned, the petitioner had sought disclosure of the material or the source of information on the basis of which such notice was issued. The petitioner denied having deposited the aforesaid amount in his bank account. The material/source of information was not supplied to the petitioner. Even if the amount of Rs.40,00,000/-as mentioned in the notice dated 23.03. 2022  is excluded from consideration for the reason that the petitioner is not the purchaser of the property in question, the amount remaining for consideration is Rs.20,71,500/-and Rs.16,20,000/-thus totaling Rs.36,91,500/-. In this regard, if the provisions of Section 149(1)(b) of the Act of 1961 are considered, it is seen that only if the amount in question that is likely to have escaped assessment is Rs.50,00,000/-or more, the time limit for issuing notice to re-open the assessment is three years but less than ten years. Thus if the income that is likely to escape assessment is only Rs.36,91,500/-after excluding the amount of Rs.40,00,000/-, it is clear that the proceedings are not liable to be re-opened as the amount involved is less than the one contemplated under Section 149(1)(b) of the Act of 1961 and the same pertains to Assessment Year 2015-16. The notice under Section 148(b) is dated 23.03. 2022  which is beyond the permissible period of three years. Court also held that it would be futile to require the petitioner to face proceedings under Section 148 of the Act of 1961. The material on record that was placed before the Assessing Officer warranted consideration especially in the light of the fact that the document relied was a registered sale deed. If the amount of Rs.40,00,000/- mentioned therein is excluded from consideration, the notice as issued on 23.03.2022  falls foul of the provisions of Section 149(1)(b) of the Act of 1961. Hence for this reason, Court did  not find that the petitioner should be required to further contest the proceedings under Section 148 of the Act of 1961. The order dated 31.03.2022 passed under Section 148 A(d) of the Income Tax Act, 1961 as well as notice dated 31.03.2022 issued under Section 148 of the Act of 1961 are quashed and set aside. (AY. 2015-16)