ORDER

Per N.V. Vasudevan, Vice President

These are appeals by the three different assessees against three different orders dated 27.11.2017 and 22.11.2017 of CIT(Appeals)-5, Bengaluru, and dated 03.01.2018 of CIT(Appeals)-10, Bengaluru, all relating to assessment year 2008-09. Since some common issues are involved in these appeals, they were heard together and we deem it convenient to pass a common order.

2. We shall first take up for consideration the appeals in ITA No.1798 & 1203/Bang/2018 in which the two assessees have challenged the validity of notice issued u/s. 148 of the Income-Tax Act, 1961 [“the Act”] as bad in law on the ground that it is issued beyond a period of six years from the end of relevant assessment year.

3. The assessees in both these appeals are individuals. Notice u/s. 148 of the Act was issued to both the assessees dated 31.03.2015 by the AO for the purpose of making a reassessment u/s. 147 of the Act in respect of income that has escaped assessment. As per the provisions of section 148 of the Act, before making a reassessment u/s. 147, the AO has to serve on the assessee notice requiring him to furnish a return. Section 149 of the Act prescribes time limit for