https://www.taxtmi.com/caselaws?id=788987 For reassessment beyond three years in a search case, the recorded reasons must themselves show that the escaped income is represented in the nature of an asset for the relevant year; a later year's material cannot cure that jurisdictional defect, so the AY 2013-14 notice and the linked special audit direction were quashed. By contrast, where the recorded reasons for AY 2015-16 identified a receivable arising from a reimbursement right, the notice was treated as within limitation because receivables can constitute an asset, and the special audit direction was sustained because the statutory preconditions under Section 142(2A) were objectively met on account of account complexity, discrepancies, missing entries, and doubts about correctness. en-us Mon, 30 Mar 2026 00:00:00 +0530 Tue, 31 Mar 2026 11:16:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788987 For reassessment beyond three years in a search case, the recorded reasons must themselves show that the escaped income is represented in the nature of an asset for the relevant year; a later year's material cannot cure that jurisdictional defect, so the AY 2013-14 notice and the linked special audit direction were quashed. By contrast, where the recorded reasons for AY 2015-16 identified a receivable arising from a reimbursement right, the notice was treated as within limitation because receivables can constitute an asset, and the special audit direction was sustained because the statutory preconditions under Section 142(2A) were objectively met on account of account complexity, discrepancies, missing entries, and doubts about correctness. Case-Laws Income Tax Mon, 30 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788987