Preliminary reassessment proceedings generally require statutory remedies unless jurisdiction is wholly absent or mandatory conditions are patently br...
Agricultural land classification requires cumulative factual indicators, while industrial-purpose land and absent agricultural use defeat reinvestment...
Reassessment beyond three years under section 149(1)(b) was unavailable because the Assessing Officer did not possess material showing escapement of income represented in the form of an asset of fifty lakh rupees or more. The order under section 148A(d) was found non-speaking, as it failed to explain why the housing loan sanction letter, bank statements and other supporting documents were unacceptable; the property purchase was substantially explained by the loan, and any remaining unexplained amount stayed below the statutory threshold. The notice under section 148 was therefore barred by limitation, the reopening was treated as a roving and fishing enquiry, and the section 148A(d) order, notice under section 148, and consequential assessment under section 147 were quashed.
Reassessment beyond three years under section 149(1)(b) was unavailable because the Assessing Officer did not possess material showing escapement of income represented in the form of an asset of fifty lakh rupees or more. The order under section 148A(d) was found non-speaking, as it failed to explain why the housing loan sanction letter, bank statements and other supporting documents were unacceptable; the property purchase was substantially explained by the loan, and any remaining unexplained amount stayed below the statutory threshold. The notice under section 148 was therefore barred by limitation, the reopening was treated as a roving and fishing enquiry, and the section 148A(d) order, notice under section 148, and consequential assessment under section 147 were quashed.
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