Reassessment jurisdiction fails where notices rely on pooled third-party material, mechanical approval, or reopening on unchanged information.
Reassessment beyond the normal limitation under Sections 148 and 149 requires assessee-specific material showing escaped income at the prescribed threshold, represented by a qualifying asset, expenditure, or book entry. Pooled seized data relating to group entities, without entity-wise attribution or net-income analysis, does not meet those jurisdictional conditions. Where material is seized from another person, bypassing Section 148A also requires compliance with applicable statutory requirements. Approval under Section 151 must be independently considered rather than mechanical. Reopening after prior proceedings were closed on the same material requires fresh information; otherwise, the renewed notice lacks jurisdiction.
Issues: (i) Whether notices under Section 148 for AYs 2015-16 to 2018-19, issued beyond three years, satisfied the extended limitation conditions and valid sanction requirements; (ii) Whether a fresh notice under Section 148 for AY 2019-20 could be issued on the same material after the earlier reassessment proceedings had been dropped.
Issue (i): Whether notices under Section 148 for AYs 2015-16 to 2018-19, issued beyond three years, satisfied the extended limitation conditions and valid sanction requirements.
Analysis: Section 149(1)(b) permits reassessment beyond the normal limitation only where the material in the Assessing Officer's possession reveals assessee-specific escaped income of at least the prescribed threshold, represented by an asset, qualifying expenditure, or entries in books of account. The seized laptop data comprised pooled cash receipts and payments concerning group entities, did not identify income attributable to the assessee, did not represent an existing asset, and was not in the nature of books of account. Reliance on gross receipts without examining payments, determining net income, or making entity-wise allocation showed borrowed satisfaction and non-application of mind regarding the jurisdictional conditions for reassessment.
Analysis: The material relied upon had been seized in a separate search of the accounts manager, rather than in the assessee's search. The exception from the procedure under Section 148A was therefore unavailable without satisfying the requirements applicable to material seized from another person. The sanction under Section 151 mechanically accepted the proposal despite the absence of material showing satisfaction of Section 149(1)(b); such mechanical sanction did not constitute the required independent approval.
Conclusion: The notices under Section 148 for AYs 2015-16 to 2018-19 and the consequential reassessment proceedings were invalid and quashed, in favour of the assessee.
Issue (ii): Whether a fresh notice under Section 148 for AY 2019-20 could be issued on the same material after the earlier reassessment proceedings had been dropped.
Analysis: The fresh notice was founded on the same search material as the earlier proceedings, which had been dropped owing to the Assessing Officer's failure to proceed with scrutiny. No fresh material or change in facts justified reopening proceedings already closed. The jurisdictional defects concerning limitation, the absence of qualifying material under Section 149(1)(b), and the sanction requirements also applied to this year.
Conclusion: The second notice under Section 148 for AY 2019-20 was invalid and quashed, in favour of the assessee.
Final Conclusion: Reassessment jurisdiction was unavailable for all the relevant assessment years because the statutory preconditions for reopening were not fulfilled and the later reopening was based on material already used in proceedings that had been closed.
Ratio Decidendi: Reassessment jurisdiction must rest on assessee-specific material satisfying the statutory preconditions and meaningful independent approval; it cannot be exercised on borrowed satisfaction or re-exercised after closure on the same material without fresh information.