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Reopening of assessment beyond three years requires sanction from Principal Chief Commissioner of Income Tax, whereas the assessee obtained sanction from Principal Commissioner of Income Tax, rendering it invalid as per the Siemens Financial Services case. The alleged escaped income of Rs. 9,00,000/- is below Rs. 50,00,000/-, barring the notice u/s 148 due to limitation u/s 149(1)(b), as held in Ganesh Dass Khanna case, where the extended ten-year period applies only for serious tax evasion cases with concealment of income above Rs. 50 lakhs. Consequently, the impugned notice issued u/s 148 is without jurisdiction and set aside, making the resultant reassessment order null and void, decided in favor of the assessee.
Reopening of assessment beyond three years requires sanction from Principal Chief Commissioner of Income Tax, whereas the assessee obtained sanction from Principal Commissioner of Income Tax, rendering it invalid as per the Siemens Financial Services case. The alleged escaped income of Rs. 9,00,000/- is below Rs. 50,00,000/-, barring the notice u/s 148 due to limitation u/s 149(1)(b), as held in Ganesh Dass Khanna case, where the extended ten-year period applies only for serious tax evasion cases with concealment of income above Rs. 50 lakhs. Consequently, the impugned notice issued u/s 148 is without jurisdiction and set aside, making the resultant reassessment order null and void, decided in favor of the assessee.
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