2026 (2) TMI 935

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...."the Ld.CIT(A)]. 2. Ground No. 1 is general in nature and does not require any specific adjudication. Ground No. 2 to 3 are against the order of Ld. CIT(A) upholding the assessment which has been invalidly reopened and is not in accordance with the provision of section 149(1)(b) of the Act. 3. The facts in brief are that the assessee has not filed return of income for the assessment year 2017-18. The notice u/s 148 was issued on 21.03.2024 after passing the order u/s 148A(d) of the Act dated 21.03.2024. The assessee in compliance filed return of income declaring total income at Rs. 2,00,130/- on 23.03.2024. Admittedly, the case of the assessee was reopened after a period of more than 3 years from the end of the relevant assessment ....

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....ree years have elapsed from the end of the relevant assessment year, unless the case falls under clause (b); (b) if three years, but not more than ten years, have elapsed from the end of the relevant assessment year unless the Assessing Officer has in his possession books of account or other documents or evidence which reveal that the income chargeable to tax, represented in the form of (i) an asset; (ii) expenditure in respect of a transaction or in relation to an event or occasion or (iii) an entry or entries in the books of account, which has escaped assessment amounts to or is likely to amount to fifty lakh rupees or more:" 6. A perusal of the above section clearly reveals that the case of the asse....