Reassessment threshold under Section 148 is only a trigger at notice stage; later additions below it do not invalidate the notice.

For initiating reassessment under Section 148, the statutory monetary threshold operates as a jurisdictional trigger based on provisional satisfaction and recorded material, not as a condition that must be conclusively proved at the notice stage. The assessment at initiation is provisional, and the final quantum of escaped income may emerge only during reassessment. The notice is therefore not invalid merely because the eventual addition is estimated to be below the threshold. The Delhi HC accordingly upheld the Section 148 notice and rejected the challenge to reassessment.

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Issues: Whether reassessment action under Section 148 of the Income-tax Act, 1961 was liable to be quashed on the ground that the income likely to have escaped assessment was ultimately estimated to be below INR 50 lakh.

Analysis: The threshold of INR 50 lakh was held to be only a trigger for commencement of reassessment proceedings and not a condition that must be conclusively established at the stage of initiation. The Court held that the assessment at the notice stage is provisional, and the ultimate quantum of escaped income may emerge only during the reassessment proceedings. Reliance was placed on the principle that where the statutory threshold is expressed in terms of income that has escaped assessment or is likely to escape assessment, the formation of opinion at the initiation stage must rest on material and recorded satisfaction, but the notice is not invalidated merely because the final addition may fall below the threshold.

Conclusion: The reassessment challenge failed, and the notice under Section 148 was held to be valid.

Ratio Decidendi: For initiating reassessment, the statutory monetary threshold operates as a jurisdictional trigger based on provisional satisfaction, and the proceedings are not invalid merely because the eventual additions are assessed at a figure below that threshold.

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