ITAT held that reopening of assessment u/s 147 beyond 3 years is...

ITAT held that reopening of assessment u/s 147 beyond 3 years is impermissible when tax evasion does not exceed Rs. 50,00,000. Relying on precedents from Delhi HC and Bombay HC, the tribunal quashed the reassessment notice u/s 148A(d) and 148, finding the proceedings invalid. The AO's best judgment assessment, which added unexplained investment and stamp duty value differences, was set aside. The assessee's appeal was allowed, rendering subsequent grounds academic, effectively nullifying the extended assessment proceedings.