Escaped income from an asset outside India – Retrospective Section 149(1)(c) is Valid

DCIT Vs Dilip J Thakkar (ITAT Mumbai)

Section 149(1)(c) provides that no notice for reassessment can be issued if “more than sixteen years, have elapsed from the end of the relevant assessment year unless the income in relation to any asset (including financial interest in any entity) located outside India, chargeable to tax, has escaped assessment”. Therefore, as long as sixteen years from the end of the relevant assessment year have not expired, the reassessment notice is in a case involving income from assets located outside India.

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