https://www.taxtmi.com/caselaws?id=779629 ITAT DELHI - AT held the notice issued u/s 148 invalid and quashed reassessment proceedings because the AO failed the requirement that escaped income be represented in the form of an asset under s.149(1)(b). The tribunal found disallowance of expenditure did not amount to an asset; therefore reopening after three years was barred by limitation. The panel treated the post-2021 amendment to s.149(1)(b) as prospective in light of a HC decision, and allowed the assessee's ground in the cross-objection. en-us Tue, 30 Sep 2025 00:00:00 +0530 Thu, 09 Oct 2025 08:54:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779629 ITAT DELHI - AT held the notice issued u/s 148 invalid and quashed reassessment proceedings because the AO failed the requirement that escaped income be represented in the form of an asset under s.149(1)(b). The tribunal found disallowance of expenditure did not amount to an asset; therefore reopening after three years was barred by limitation. The panel treated the post-2021 amendment to s.149(1)(b) as prospective in light of a HC decision, and allowed the assessee's ground in the cross-objection. Case-Laws Income Tax Tue, 30 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779629