Bank account credits used to reopen tax assessment after three years-section 149(1)(b) ₹50 lakh threshold not met; reopening quashed.

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....Reassessment initiated beyond three years was tested against the statutory precondition in section 149(1)(b) that the AO must have material to form a reasonable belief that income escaping assessment was likely to be Rs.50 lakh or more. The tribunal held that "likely to amount" cannot be inferred merely from gross bank transactions without a preliminary analysis of the nature of entries and the taxable component. On the facts, even treating the credits as receipts yielding commission income, the taxable income could not reasonably exceed Rs.50 lakh, and the ultimately assessed escaped income was far below the threshold. The reopening was therefore barred by limitation and without jurisdiction; the appeal was allowed. - ITAT....