Escapement Below ₹50 Lakh: ITAT Ahmedabad Holds Reopening Beyond 3 Years Invalid

Sunny Fulchandji Shah Vs DCIT (ITAT Ahmedabad) ITAT Ahmedabad: Reopening Beyond Three Years Invalid Where Escapement Is Below ₹50 Lakh—Section 80GGC Disallowance Falls The Income Tax Appellate Tribunal allowed the assessee’s appeal for AY 2019-20 and quashed the reassessment proceedings as void ab initio, holding that the notice under section 148 issued on 20.04.2023 was time-barred under section 149. The reopening was based on an alleged bogus political donation of ₹5 lakh claimed under section 80GGC. The Tribunal noted that for AY 2019-20, a notice issued after three years can be sus...