Allowing the petition the Court held that according to section 149 of the Income-tax Act, 1961 the limitation for Held, allowing the petition, that the notice dated July 21, 2022, issued under section 148, for the assessment year 2016-17 was barred by the limitation period prescribed under section 149 since the three-year time period had ended on March 31, 2020. Further, the notice was for alleged escaped income which was less than Rs. 50 lakhs and therefore, the benefit of the extended period of limitation beyond three years till ten years was not available. The initiation of reassessment proceedings under section 147 was without jurisdiction. If the foundation of any proceeding was illegal and unsustainable, all consequential proceedings or orders were also bad in law. Accordingly, since the notice dated July 21, 2022, issued under section 148, was barred by limitation and was illegal, unsustainable and void ab initio and set aside, the subsequent reassessment order under section 147 and notice of demand under section 156 were also quashed and set aside.  (AY.2016-17)