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The AI analyses your query, notice, order, or uploaded documents and identifies the key issues involved.

• Review the issues identified by the AI
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Step 2 – Draft Generation

Once you approve the issues, the AI performs issue-wise legal research and prepares a structured draft response.

• Relevant statutory provisions
• Judicial precedents and Supreme Court, High Court and other citations
• Issue-wise legal analysis
• Practical arguments and supporting content
• Professionally structured draft ready for further review.

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Tax Authorities Cannot Reopen Assessment Beyond 3 Years When Tax Evasion Is Less Than Rs. 50 Lakh

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....ITAT held that reopening of assessment u/s 147 beyond 3 years is impermissible when tax evasion does not exceed Rs. 50,00,000. Relying on precedents from Delhi HC and Bombay HC, the tribunal quashed the reassessment notice u/s 148A(d) and 148, finding the proceedings invalid. The AO's best judgment assessment, which added unexplained investment and stamp duty value differences, was set aside. The assessee's appeal was allowed, rendering subsequent grounds academic, effectively nullifying the extended assessment proceedings.....

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Tax Authorities Cannot Reopen Assessment Beyond 3 Years When Tax Evasion Is Less Than Rs. 50 Lakh