Reopening Past Assessments Requires Tangible Evidence of Income Escapement Beyond Rs.50 Lakh; Valuation Report Insufficient.

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Full Text of the Document

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....The assessment years beyond six years but not exceeding ten years can be reopened u/s 153A only if the Assessing Officer possesses evidence depicting escapement of income aggregating Rs.50,00,000/- or more in such relevant assessment years. These provisions extending the assessment period beyond six years up to ten years impose a stringent condition of the Assessing Officer possessing evidence of escapement of income of Rs.50,00,000/- or more. Such provisions must be construed strictly, and the evidence relied upon by the Assessing Officer in such extended period assessments must be tangible. The Departmental Valuation Officer's report on a standalone basis without corroborating material cannot be construed as incriminating material, and ad.........