https://www.taxtmi.com/caselaws?id=784702 Reassessment under s.147 was challenged as time-barred under s.149 because the alleged escapement of income did not reach the ?50 lakh threshold after three years. The Tribunal held that where the assessee had already furnished complete investment details and the AO's material could not support a conclusion that income chargeable to tax of ?50 lakh or more had escaped assessment, the case fell within s.149(1)(a) and not s.149(1)(b). Applying the jurisdictional HC view that the ?50 lakh requirement is a threshold jurisdictional fact for extended limitation, the s.148 notice was held invalid and all consequential proceedings were declared void ab initio. en-us Mon, 01 Dec 2025 00:00:00 +0530 Sat, 10 Jan 2026 08:25:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784702 Reassessment under s.147 was challenged as time-barred under s.149 because the alleged escapement of income did not reach the ?50 lakh threshold after three years. The Tribunal held that where the assessee had already furnished complete investment details and the AO's material could not support a conclusion that income chargeable to tax of ?50 lakh or more had escaped assessment, the case fell within s.149(1)(a) and not s.149(1)(b). Applying the jurisdictional HC view that the ?50 lakh requirement is a threshold jurisdictional fact for extended limitation, the s.148 notice was held invalid and all consequential proceedings were declared void ab initio. Case-Laws Income Tax Mon, 01 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784702