Assessee challenged show-cause notice issued under section 148 on ground that preconditions for issue of notice under section 148 had not been satisfied before issuance of such notice. it was  submitted that in view of provisions of reopening having undergone amendment by Finance Act, 2021, reassessment would not be permissible after expiry of six years as escaped assessment amount was less than Rs. 50 lakhs. The  Revenue contended  that   the  notice had been issued on basis of information regarding sale deed of land that was received by revenue.  As per sale deed available on record, assessee had sold a piece of land for a consideration of Rs. 6.51 lakhs and market value of such land for stamp duty purpose was determined at Rs. 51.71 lakhs.  However, for year under consideration assessee’s return of income was not filed, hence, capital gain on consideration of aforesaid land remained undisclosed. Dismissing the petition the Court held that   the Assessing Officer having formed opinion that reassessment was necessary, as income had escaped assessment and valuation of escaped assessment was more than Rs. 50 lakhs based and had also recorded reasons, it was for assessee to establish that view taken by Assessing Officer was contrary to material on record or it was perverse. Since challenge to show-cause notice was based on disputed questions of facts. The petition was dismissed.  entertained.  (AY. 2015-16)