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ITAT held reassessment notice u/s 148 invalid where income escaped assessment was Rs. 22,32,379, below the Rs. 50,00,000 threshold required under Section 149(1)(b) for reopening beyond three years. The tribunal rejected revenue's contention that total sale consideration should be considered, emphasizing that only income chargeable to tax which escaped assessment for the specific year determines validity. Relying on Sanath Kumar Murali precedent, ITAT clarified the threshold applies to escaped income for the impugned year, not entire transaction value. Since escaped assessment quantum fell significantly below statutory limit, notice was quashed as bad in law. Consequential assessment order was also invalidated, rendering remaining grounds academic. Assessee's appeal allowed entirely.
ITAT held reassessment notice u/s 148 invalid where income escaped assessment was Rs. 22,32,379, below the Rs. 50,00,000 threshold required under Section 149(1)(b) for reopening beyond three years. The tribunal rejected revenue's contention that total sale consideration should be considered, emphasizing that only income chargeable to tax which escaped assessment for the specific year determines validity. Relying on Sanath Kumar Murali precedent, ITAT clarified the threshold applies to escaped income for the impugned year, not entire transaction value. Since escaped assessment quantum fell significantly below statutory limit, notice was quashed as bad in law. Consequential assessment order was also invalidated, rendering remaining grounds academic. Assessee's appeal allowed entirely.
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