Infrastructure facility: energy-efficient public lighting held integral to road projects, qualifying the operator as a developer and eligible for dedu...
Fourth Proviso to Section 153A: extended-period inquiry requires a reasonable, material-based satisfaction that escaped income likely exceeds the thre...
Reopening of assessment under the new regime requires prior sanction by a specified senior authority where reassessment is sought after three years; if income escaping assessment is below the Rs.50,00,000 threshold, no reassessment notice may be issued after three years. Here the alleged escaped income was Rs.10,25,756 and the notice was issued beyond three years with approval only from the Principal Commissioner, which does not meet the prescribed sanctioning requirement; the ITAT held the section 148 notice and consequent reassessment proceedings invalid and quashed them, allowing the assessee's appeal.
Reopening of assessment under the new regime requires prior sanction by a specified senior authority where reassessment is sought after three years; if income escaping assessment is below the Rs.50,00,000 threshold, no reassessment notice may be issued after three years. Here the alleged escaped income was Rs.10,25,756 and the notice was issued beyond three years with approval only from the Principal Commissioner, which does not meet the prescribed sanctioning requirement; the ITAT held the section 148 notice and consequent reassessment proceedings invalid and quashed them, allowing the assessee's appeal.
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