Tax Authorities Cannot Reopen Assessment Beyond 3 Years When Tax Evasion Is Less Than Rs. 50 Lakh

Tax Authorities Cannot Reopen Assessment Beyond 3 Years When Tax Evasion Is Less Than Rs. 50 Lakh https://www.taxtmi.com/highlights?id=88255 ITAT held that reopening of assessment u/s 147 beyond 3 years is impermissible when tax evasion does not exceed Rs. 50,00,000. Relying on precedents from Delhi HC and Bombay HC, the tribunal quashed the reassessment notice u/s 148A(d) and 148, finding the proceedings invalid. The AO's best judgment assessment, which added unexplained investment and stamp duty value differences, was set aside. The assessee's appeal was allowed, rendering subsequent grounds academic, effectively nullifying the extended assessment proceedings. en-us Sat, 10 May 2025 08:36:36 +0530 Sat, 10 May 2025 08:37:18 +0530 TaxTMI RSS Generator Tax Authorities Cannot Reopen Assessment Beyond 3 Years When Tax Evasion Is Less Than Rs. 50 Lakh https://www.taxtmi.com/highlights?id=88255 ITAT held that reopening of assessment u/s 147 beyond 3 years is impermissible when tax evasion does not exceed Rs. 50,00,000. Relying on precedents from Delhi HC and Bombay HC, the tribunal quashed the reassessment notice u/s 148A(d) and 148, finding the proceedings invalid. The AO's best judgment assessment, which added unexplained investment and stamp duty value differences, was set aside. The assessee's appeal was allowed, rendering subsequent grounds academic, effectively nullifying the extended assessment proceedings. Highlights Income Tax Sat, 10 May 2025 08:36:36 +0530 https://www.taxtmi.com/highlights?id=88255