https://www.taxtmi.com/caselaws?id=447970 The Rajasthan HC quashed reassessment proceedings under Section 147. The tax authority issued notice under Section 148A invoking extended limitation period assuming cash deposits of Rs.59,75,000. However, actual cash transactions were only Rs.33,62,000, below the Rs.50,00,000 threshold. Since the notice was issued after three years and the amount was below the threshold, proceedings were barred by limitation under Section 149(1)(a). The authority mechanically rejected the assessee's submissions and impermissibly converted proceedings to Section 69A read with Section 115BBE. The court held that once Section 148A notice is time-barred, no further proceedings under any provision can be initiated. Petition allowed in favor of assessee. en-us Thu, 04 Jan 2024 00:00:00 +0530 Mon, 08 Jan 2024 16:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=447970 The Rajasthan HC quashed reassessment proceedings under Section 147. The tax authority issued notice under Section 148A invoking extended limitation period assuming cash deposits of Rs.59,75,000. However, actual cash transactions were only Rs.33,62,000, below the Rs.50,00,000 threshold. Since the notice was issued after three years and the amount was below the threshold, proceedings were barred by limitation under Section 149(1)(a). The authority mechanically rejected the assessee's submissions and impermissibly converted proceedings to Section 69A read with Section 115BBE. The court held that once Section 148A notice is time-barred, no further proceedings under any provision can be initiated. Petition allowed in favor of assessee. Case-Laws Income Tax Thu, 04 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=447970