https://www.taxtmi.com/caselaws?id=462088 ITAT Kolkata quashed the reassessment order on multiple grounds. The notice u/s 148 was issued by non-jurisdictional ITO instead of ACIT/DCIT who had proper jurisdiction over the returned income of Rs. 39,72,460. The notice dated 30.06.2021 was barred by limitation as it was issued after 31.03.2021 under the old regime which ceased to apply post-amendment. Additionally, the AO lacked jurisdiction under section 149(1)(b) as the escaped income was only Rs. 13 lakh, below the Rs. 50 lakh threshold, without supporting documents evidencing higher amounts. The AO failed to apply mind to the assessee's reply controverting allegations of accommodation entries. The assessment was declared invalid and quashed in favor of the assessee. en-us Mon, 29 Jul 2024 00:00:00 +0530 Tue, 20 May 2025 17:06:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462088 ITAT Kolkata quashed the reassessment order on multiple grounds. The notice u/s 148 was issued by non-jurisdictional ITO instead of ACIT/DCIT who had proper jurisdiction over the returned income of Rs. 39,72,460. The notice dated 30.06.2021 was barred by limitation as it was issued after 31.03.2021 under the old regime which ceased to apply post-amendment. Additionally, the AO lacked jurisdiction under section 149(1)(b) as the escaped income was only Rs. 13 lakh, below the Rs. 50 lakh threshold, without supporting documents evidencing higher amounts. The AO failed to apply mind to the assessee's reply controverting allegations of accommodation entries. The assessment was declared invalid and quashed in favor of the assessee. Case-Laws Income Tax Mon, 29 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462088