Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
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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