Time limit for notice [Section 149] under Income escaping assessment [Section 147] :

Notice under section 148 must be issued within the following time limit:

(a) Where the income which has escaped assessment amounts to or is likely to amount to Rs 1 lakh or more, the notice under section 148 shall be issued within six years from the end of the relevant assessment year.

(b) In case income is in relation to such assets (including financial interest in any entity) located outside India has escaped assessment, an extended time limit of 16 years would be available for issue of notice under section 148 for an assessment or reassessment.

(c) In other cases, the notice shall be issued within four years from the end of the relevant assessment year.

As per section 149(3), if the person on whom a notice under section 148 is to be served is a person treated as an agent of a non-resident under section 163 and the assessment, reassessment or re-computation in pursuance of the notice is to be made on him as the agent of such non-resident, there is a time limit of six years from the end of the relevant assessment year, beyond which such notice cannot be issued. It is also clarified that the extended time limit of six years shall also be applicable for any assessment year beginning on or before 1st April, 2012.