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ITAT upheld reassessment notice under section 148 issued within six-year limitation period for AY 2015-16, finding escaped income of Rs. 45,00,000 exceeded statutory threshold. Tribunal rejected challenges regarding mechanical approval by PCIT under section 151 and improper service, noting electronic service compliance and assessee's participation in faceless assessment proceedings. However, ITAT denied section 54 exemption for property comprising four ground-floor shops and one first-floor room, ruling the predominantly commercial character disqualified it as "residential house" despite assessee's claims. Tribunal directed AO to recompute capital gains on 50% share only, recognizing joint ownership with spouse as evidenced in sale deed. Appeal partly allowed regarding computation adjustment while upholding reassessment validity and exemption denial.
ITAT upheld reassessment notice under section 148 issued within six-year limitation period for AY 2015-16, finding escaped income of Rs. 45,00,000 exceeded statutory threshold. Tribunal rejected challenges regarding mechanical approval by PCIT under section 151 and improper service, noting electronic service compliance and assessee's participation in faceless assessment proceedings. However, ITAT denied section 54 exemption for property comprising four ground-floor shops and one first-floor room, ruling the predominantly commercial character disqualified it as "residential house" despite assessee's claims. Tribunal directed AO to recompute capital gains on 50% share only, recognizing joint ownership with spouse as evidenced in sale deed. Appeal partly allowed regarding computation adjustment while upholding reassessment validity and exemption denial.
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