https://www.taxtmi.com/caselaws?id=770173 The HC held that reassessment proceedings initiated under Sections 147/148 were invalid as the preconditions under Section 149(1A) of the Income Tax Act were not met. It reiterated that, post-2021, escaped income exceeding Rs. 50 lakhs may be computed cumulatively over multiple years only where such income is represented by an "asset" or by "expenditure in relation to an event or occasion." On the facts, the Revenue failed to establish that the alleged escaped income was so represented. Consequently, the notice under Section 148 was issued beyond the permissible limitation period under Section 149(1)(b), rendering the reassessment without jurisdiction. The reassessment proceedings were quashed and the petition allowed. en-us Fri, 25 Apr 2025 00:00:00 +0530 Tue, 02 Dec 2025 18:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=770173 The HC held that reassessment proceedings initiated under Sections 147/148 were invalid as the preconditions under Section 149(1A) of the Income Tax Act were not met. It reiterated that, post-2021, escaped income exceeding Rs. 50 lakhs may be computed cumulatively over multiple years only where such income is represented by an "asset" or by "expenditure in relation to an event or occasion." On the facts, the Revenue failed to establish that the alleged escaped income was so represented. Consequently, the notice under Section 148 was issued beyond the permissible limitation period under Section 149(1)(b), rendering the reassessment without jurisdiction. The reassessment proceedings were quashed and the petition allowed. Case-Laws Income Tax Fri, 25 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=770173