Reassessment threshold limits extended reopening where only embedded profit from unaccounted purchases constitutes escaped income.
X X X X Extracts X X X X
X X X X Extracts X X X X
....Reassessment beyond three years requires escaped income to meet the statutory threshold; where unaccounted purchases had corresponding sales and the embedded profit was separately assessed, only that profit constituted escaped income. Reassessment notices for AY 2014-15 to AY 2018-19 were therefore quashed. Material seized during a third-party search required notice under section 148 before assessment, rendering the direct AY 2022-23 assessment void. No cross-examination breach arose without a specific request, and the pre-amendment reassessment regime permitted a 30-day return period. Where corresponding sales were accepted, tax applied only to embedded profit, not the full unaccounted purchase value.....
TaxTMI