Reassessment barred by limitation where escaped income was below the statutory threshold and reopening was initiated after three years.

Reassessment under Section 148A(b) was impermissible where the notice disclosed escaped income below the statutory threshold of Rs. 50 lakhs and the proposed reopening was initiated beyond three years from the end of the relevant assessment year. The Court held that Section 149(1)(a) barred such reopening in these circumstances, and the order under Section 148A(d) could not be sustained. The reassessment initiation was therefore without jurisdiction and was quashed.

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Issues: Whether the reassessment proceeding initiated under Section 148A(b) and culminated in an order under Section 148A(d) of the Income-tax Act, 1961 was sustainable when the escaped income disclosed in the notice was below Rs.50 lakhs and the reopening was beyond the period prescribed under Section 149(1)(a).

Analysis: The notice under Section 148A(b) recorded escaped income of Rs.22,66,575/-, which was below the statutory threshold of Rs.50 lakhs. In such circumstances, reopening beyond three years from the end of the relevant assessment year was impermissible under Section 149(1)(a). The revenue was unable to justify the impugned order under Section 148A(d).

Conclusion: The reassessment proceeding was without jurisdiction and liable to be quashed.

Final Conclusion: The writ petition succeeded and the reassessment initiation was annulled.

Ratio Decidendi: Reassessment beyond the prescribed limitation period is barred where the escaped income does not exceed the statutory monetary threshold, and any proceeding initiated contrary to that bar is without jurisdiction.

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