https://www.taxtmi.com/caselaws?id=792906 Reassessment notice under section 148 was held time-barred because reopening beyond three years did not satisfy section 149(1)(b), as the alleged escaped income from a donation did not involve an asset, expenditure, or entry of fifty lakh rupees or more. The period given in the section 148A(b) show-cause notice had to be excluded while computing limitation, and on the stated dates the final notice was issued beyond the permissible limit. The sixth proviso to section 149(1) was held inapplicable because no reply was filed to the section 148A(b) notice. The reassessment challenge succeeded on limitation, while merits were left open. en-us Tue, 19 May 2026 00:00:00 +0530 Fri, 05 Jun 2026 08:07:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792906 Reassessment notice under section 148 was held time-barred because reopening beyond three years did not satisfy section 149(1)(b), as the alleged escaped income from a donation did not involve an asset, expenditure, or entry of fifty lakh rupees or more. The period given in the section 148A(b) show-cause notice had to be excluded while computing limitation, and on the stated dates the final notice was issued beyond the permissible limit. The sixth proviso to section 149(1) was held inapplicable because no reply was filed to the section 148A(b) notice. The reassessment challenge succeeded on limitation, while merits were left open. Case-Laws Income Tax Tue, 19 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792906