Reopening After 3 Years Invalid If Escapement Is Below ₹50 Lakh

Sanjay Champalal Jaiswal Vs ITO (ITAT Pune) Reopening Beyond Three Years Invalid Where Escapement Is Below ₹50 Lakh — ITAT Pune Quashes Reassessment The Pune SMC Bench of the ITAT quashed the reassessment for AY 2016-17, holding that the notice under section 148 dated 27-07-2022 was without jurisdiction, as the alleged income escaping assessment was ₹49.01 lakh, i.e. below the statutory threshold of ₹50 lakh prescribed under section 149. Key findings of the Tribunal: Statutory bar under section 149: After expiry of three years from the end of the relevant assessment year, a notice u/s...