Reassessment limitation and escaped-income threshold defeated reopening where property investment evidence did not meet the statutory limit.

Reassessment under sections 148A and 148 was unsustainable because the section 148A(d) order did not meaningfully address the assessee's reply and supporting documents regarding the source of immovable property investment. The extended limitation under section 149(1)(b) applies only where the Assessing Officer possesses books, documents, or evidence showing escaped income represented in the form of an asset of fifty lakh rupees or more. On the facts, the material did not meet that statutory threshold, as the alleged unexplained component was far below the limit and the full purchase value could not be treated as escaped income. The reopening and the assessment under section 147 were therefore quashed.

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Issues: Whether the reassessment proceedings initiated under section 148A and the consequential notice under section 148 for assessment year 2015-16 were valid, and whether the assessment was barred by limitation for want of material showing escaped income of fifty lakh rupees or more.

Analysis: The assessee had replied to the show-cause notice under section 148A(b) by explaining the source of the immovable property investment through housing loan and personal savings and had filed supporting documents. The order under section 148A(d) did not deal with these materials in a reasoned manner and proceeded on a perfunctory approach. For invocation of the extended period under section 149(1)(b), the Assessing Officer must have in possession books, documents, or evidence revealing that income chargeable to tax represented in the form of an asset has escaped assessment and amounts to or is likely to amount to fifty lakh rupees or more. On the facts, the material did not satisfy that threshold, and the reopening could not be sustained by treating the full property purchase as escaped income when the explanation showed substantial financed investment and the alleged unexplained component, if any, was far below the statutory limit.

Conclusion: The reopening under sections 148A and 148 was held invalid and time-barred, and the assessment under section 147 was quashed in favour of the assessee.

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