https://www.taxtmi.com/caselaws?id=757659 The ITAT Mumbai held that the reopening of assessment beyond three years was invalid on two grounds. First, the sanction was improperly obtained from Pr. CIT instead of the required Pr. CCIT for assessments reopened beyond three years, following Siemens Financial Services precedent. Second, the notice under section 148 was barred by limitation as the alleged income escapement of Rs. 9,00,000 was below the Rs. 50,00,000 threshold required for extended limitation period under section 149(1)(b), citing Ganesh Dass Khanna judgment. The tribunal ruled the notice was issued without jurisdiction and set aside the reassessment order as null and void, deciding in favor of the assessee. en-us Tue, 20 Aug 2024 00:00:00 +0530 Thu, 29 Aug 2024 11:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757659 The ITAT Mumbai held that the reopening of assessment beyond three years was invalid on two grounds. First, the sanction was improperly obtained from Pr. CIT instead of the required Pr. CCIT for assessments reopened beyond three years, following Siemens Financial Services precedent. Second, the notice under section 148 was barred by limitation as the alleged income escapement of Rs. 9,00,000 was below the Rs. 50,00,000 threshold required for extended limitation period under section 149(1)(b), citing Ganesh Dass Khanna judgment. The tribunal ruled the notice was issued without jurisdiction and set aside the reassessment order as null and void, deciding in favor of the assessee. Case-Laws Income Tax Tue, 20 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757659