https://www.taxtmi.com/caselaws?id=783638 Reassessment initiated beyond three years was tested against the statutory precondition in s.149(1)(b) that income escaping assessment must amount to, or be likely to amount to, at least Rs. 50 lakh. The ITAT held that "likely to amount" requires a reasonable belief founded on material and a preliminary analysis of the nature of entries, and cannot be inferred from gross bank credits alone. Here, the material showed the taxpayer earned only commission on trading receipts of Rs. 1.74 crore; even on an aggressive estimation basis, the taxable escaped income could not cross Rs. 50 lakh, and the ultimately assessed income was far below that threshold. The reopening was therefore time-barred and without jurisdiction; the appeal was allowed. en-us Wed, 17 Dec 2025 00:00:00 +0530 Fri, 19 Dec 2025 08:30:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783638 Reassessment initiated beyond three years was tested against the statutory precondition in s.149(1)(b) that income escaping assessment must amount to, or be likely to amount to, at least Rs. 50 lakh. The ITAT held that "likely to amount" requires a reasonable belief founded on material and a preliminary analysis of the nature of entries, and cannot be inferred from gross bank credits alone. Here, the material showed the taxpayer earned only commission on trading receipts of Rs. 1.74 crore; even on an aggressive estimation basis, the taxable escaped income could not cross Rs. 50 lakh, and the ultimately assessed income was far below that threshold. The reopening was therefore time-barred and without jurisdiction; the appeal was allowed. Case-Laws Income Tax Wed, 17 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783638