https://www.taxtmi.com/caselaws?id=801154 Reassessment notice issued under Section 148 more than three years after the relevant assessment year cannot rely on the extended limitation period where the assessee's attributable income escaping assessment is below the prescribed threshold. In a sale by multiple vendors, each vendor's individual share, rather than the aggregate sale consideration, determines the amount attributable to that assessee. Treating the full transaction value as income escaping assessment for one vendor is impermissible where the reassessment accepts a lower individual share. The notice was time-barred, rendering the reassessment order vitiated. en-us Wed, 09 Sep 2026 00:00:00 +0530 Fri, 16 Oct 2026 05:20:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=801154 Reassessment notice issued under Section 148 more than three years after the relevant assessment year cannot rely on the extended limitation period where the assessee's attributable income escaping assessment is below the prescribed threshold. In a sale by multiple vendors, each vendor's individual share, rather than the aggregate sale consideration, determines the amount attributable to that assessee. Treating the full transaction value as income escaping assessment for one vendor is impermissible where the reassessment accepts a lower individual share. The notice was time-barred, rendering the reassessment order vitiated. Case-Laws Income Tax Wed, 09 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801154