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 only ₹28.86 lakh and the notice u/s 148 was issued beyond three years from the end of AY 2017-18. Under the amended Sec 151, reassessment afte...