https://www.taxtmi.com/caselaws?id=798460 Section 149(1)(a) imposes a three-year limitation for reassessment notices. The extended period under section 149(1)(b) applies only where material indicates escaped income of at least Rs. 50 lakh represented by an asset, expenditure, or book entry, and its conditions require strict satisfaction. Jurisdiction under section 148A(d) must be founded on the issue that remains after considering the taxpayer's response. Where the surviving basis is denial of a deduction below the statutory threshold, rather than an allegation of unexplained deposits, the extended limitation is unavailable. A notice issued beyond three years is therefore time-barred, and the consequential reassessment lacks jurisdiction. en-us Mon, 20 Jul 2026 00:00:00 +0530 Tue, 08 Sep 2026 08:42:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798460 Section 149(1)(a) imposes a three-year limitation for reassessment notices. The extended period under section 149(1)(b) applies only where material indicates escaped income of at least Rs. 50 lakh represented by an asset, expenditure, or book entry, and its conditions require strict satisfaction. Jurisdiction under section 148A(d) must be founded on the issue that remains after considering the taxpayer's response. Where the surviving basis is denial of a deduction below the statutory threshold, rather than an allegation of unexplained deposits, the extended limitation is unavailable. A notice issued beyond three years is therefore time-barred, and the consequential reassessment lacks jurisdiction. Case-Laws Income Tax Mon, 20 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798460