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Reassessment after the ordinary limitation period requires the escaped-income threshold and independent sanction, without expanding jurisdiction throu...
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Escaped income of at least Rs. 50 lakh is a jurisdictional...
Reassessment after the ordinary limitation period requires the escaped-income threshold and independent sanction, without expanding jurisdiction through exclusions.
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Escaped income of at least Rs. 50 lakh is a jurisdictional condition for reassessment beyond the ordinary three-year period under Section 149(1)(b). Time allowed to respond to a show-cause notice and periods covered by a court-ordered stay may be excluded when computing limitation, while the sixth proviso provides a consequential minimum seven-day period. These provisions do not enlarge substantive jurisdiction. Approval under Section 151 requires independent consideration of the assessee's reply, the escaped-income quantum and the permissible reopening period. An order must stand on its recorded reasons, which cannot be supplemented for the first time in writ proceedings.
Escaped income of at least Rs. 50 lakh is a jurisdictional condition for reassessment beyond the ordinary three-year period under Section 149(1)(b). Time allowed to respond to a show-cause notice and periods covered by a court-ordered stay may be excluded when computing limitation, while the sixth proviso provides a consequential minimum seven-day period. These provisions do not enlarge substantive jurisdiction. Approval under Section 151 requires independent consideration of the assessee's reply, the escaped-income quantum and the permissible reopening period. An order must stand on its recorded reasons, which cannot be supplemented for the first time in writ proceedings.
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