ITAT Mumbai Quashes Reassessment – Sec 148 Notice Invalid Where Escapement Below Rs 50 Lakh Approval by Wrong Authority

Prabhulal Kalji Doshi Vs ITO (ITAT Mumbai)

In Prabhulal Kalji Doshi vs ITO (AY 2017-18), the ITAT Mumbai allowed the assessee’s appeal and quashed reassessment proceedings, holding that reopening under the new regime was legally invalid. The Tribunal first condoned a 79-day delay noting bona-fide reasons such as lack of awareness of proceedings and bank account attachment.

 On merits, ITAT observed that income alleged to have escaped assessment was onl

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