ITAT Mumbai: Reopening Beyond 3 Years Invalid – ₹6 Lakh Escapement Fails ₹50 Lakh Threshold

Trishladevi Mukesh Jain Vs ITO (ITAT Mumbai) In this case, the ITAT Mumbai quashed reassessment proceedings initiated under Section 147/148 on the ground of limitation under Section 149(1)(b). The Tribunal noted that the notice u/s 148 was issued on 13.07.2022 for A.Y. 2017–18, i.e., beyond the normal 3-year limitation period. For such extended reopening (up to 10 years), the law mandates that the alleged escaped income must be ₹50 lakh or more. However, in the present case, the entire basis of reopening was an alleged unexplained expenditure of only ₹6 lakh, which is far below the statu...