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Reassessment under s.147 was challenged on limitation under s.149(1), where the assessee had disclosed complete details of property investment made by her spouse and the alleged escapement did not reach the ₹50 lakh threshold. Applying the statutory scheme and precedent, the forum held that the AO must first demonstrably form a view, from record material, that income chargeable to tax of ₹50 lakh or more escaped assessment to invoke the extended time limit; otherwise, only clause (a) applies. As the assessee established that the escapement assumption exceeding ₹50 lakh was incorrect, the s.148 notice issued beyond three years was invalid and all consequential proceedings were void ab initio. - ITAT
Reassessment under s.147 was challenged on limitation under s.149(1), where the assessee had disclosed complete details of property investment made by her spouse and the alleged escapement did not reach the ₹50 lakh threshold. Applying the statutory scheme and precedent, the forum held that the AO must first demonstrably form a view, from record material, that income chargeable to tax of ₹50 lakh or more escaped assessment to invoke the extended time limit; otherwise, only clause (a) applies. As the assessee established that the escapement assumption exceeding ₹50 lakh was incorrect, the s.148 notice issued beyond three years was invalid and all consequential proceedings were void ab initio. - ITAT
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