ITAT Kolkata: Reopening Beyond Six Years Quashed – Escaped Income Less Than ₹50 Lakh

Amiya Shankar Ghar Vs ITO (ITAT Kolkata) ITAT Kolkata: Reopening Beyond Six Years Quashed – Escaped Income Less Than ₹50 Lakh; Notice u/s 148 Issued Without Jurisdiction, Reassessment Set Aside Background Assessee was a co-owner (1/9th share) in property sold for ₹1.46 Cr., his share being ₹16.27 lakh. AO reopened case u/s 147 by issuing notice u/s 148 on 27.07.2022. Assessee did not file return in response; AO proceeded with reassessment. Assessee argued reopening was illegal as it was beyond six years from end of AY 2014-15 and income allegedly escaping was far below ₹50 lakh thr...