The Tribunal held that the notice under section 148 was issued after a lapse of a period of four years from the end of the relevant assessment year. The amendment made to section 151(2), requiring the permission of the PCIT/CCIT/CIT for issue of such notices did not apply retrospectively, the law in force on the date of issuance of notice was to be applied. Hence, the Joint Commissioner, whose permission was taken for issuance of notice under section 148, was the competent authority at that time. The notice was held valid. On merit the aassesssee has not substantiated the source of deposit hence the  addition as cash credit affirmed.    (AY. 2008-09).