Section 148 Notice Invalid Beyond Three Years as Escaped Income Below ₹50 Lakh

ACIT Vs Rajiv Gupta (ITAT Hyderabad)

The Revenue filed an appeal before the ITAT Hyderabad challenging the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, dated 24 December 2024, relating to Assessment Year 2016-17. The dispute arose from the reassessment proceedings initiated under Section 147 read with Section 144B of the Income Tax Act, 1961, through a notice under Section 148 issued on 30 July 2022. The assessee had originally filed his return of income on 8 October 2016 declaring ₹90,61,122, and the case was selected for scrutiny under Sec

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