Revisional power in block assessment upheld, undisclosed search income sustained, freight suppression addition restored, accrued lorry hire liability ...
Reassessment and fee-for-technical-services classification: reopening upheld, but certain reimbursements and mobilization charges fell outside treaty ...
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ITAT held that reassessment initiated after three years from the end of AY 2017-18 could not be sustained where the alleged escaped income was only Rs. 5,00,000, because section 149(1)(b) applies only when the escaped income is, or is likely to be, Rs. 50,00,000 or more in the prescribed form. As that statutory threshold was not met, the sanction under section 151 was invalid and the notice under section 148 was bad in law, rendering the reassessment under section 147 liable to be quashed. The merits of the addition and the remaining grounds were left unadjudicated as academic.
ITAT held that reassessment initiated after three years from the end of AY 2017-18 could not be sustained where the alleged escaped income was only Rs. 5,00,000, because section 149(1)(b) applies only when the escaped income is, or is likely to be, Rs. 50,00,000 or more in the prescribed form. As that statutory threshold was not met, the sanction under section 151 was invalid and the notice under section 148 was bad in law, rendering the reassessment under section 147 liable to be quashed. The merits of the addition and the remaining grounds were left unadjudicated as academic.
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