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ITAT adjudicated a tax assessment reopening case, determining the Income Tax Officer's (ITO) jurisdiction to issue notice under Section 148. The tribunal found that since the value of income escaping assessment was below Rs. 50 lakhs, the ITO lacked legal authority to issue the notice as per Section 149(1)(b). Consistent with precedents from Bombay HC and Madhya Pradesh HC, the tribunal quashed the Section 148A(d) order and consequential assessment order, ruling the notice was procedurally invalid and without jurisdictional merit.
ITAT adjudicated a tax assessment reopening case, determining the Income Tax Officer's (ITO) jurisdiction to issue notice under Section 148. The tribunal found that since the value of income escaping assessment was below Rs. 50 lakhs, the ITO lacked legal authority to issue the notice as per Section 149(1)(b). Consistent with precedents from Bombay HC and Madhya Pradesh HC, the tribunal quashed the Section 148A(d) order and consequential assessment order, ruling the notice was procedurally invalid and without jurisdictional merit.
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