Held that the assessee had submitted that the receipt had been delayed and it was only after a few years that the amounts had been received, such submission involved the appreciation of facts which were to be best considered by the authorities. The contention of the assessee to the effect that the tax liability of the receipt had not been stated in the show-cause notice was also devoid of merit, since the assessing authority had raised these issues specifically in the penultimate paragraph of the annexure to notice under section 148A(b) of the Act. Writ petition against the notice is dismissed.  (AY.2019-20)