(1.) Appellant is the writ petitioner.
(2.) We heard Shri Anil D. Nair, learned counsel for the appellant and also Shri P.K. Ravindranath Menon, the learned senior counsel for the income tax department.
(3.) Learned counsel for the appellant would submit that Ext.P6 is vulnerable, as it is issued without jurisdiction. It is issued after the expiry of four years. He would rely on the following case law: