Notice issued u/s. 148 beyond 3 years is time barred as escapement is less than 50 Lakhs

Vatti Prakash Reddy Vs ITO (ITAT Hyderabad)

ITAT Hyderabad held that limitation for issuing notice under section 148 of the Income Tax Act would be only 3 years from the end of the assessment year since material suggesting escapement is less than Rs. 50 Lakhs. Hence, notice issued u/s. 148 is beyond period of limitation of three years hence quashed.

Facts- The present appeal has been preferred by the appellant. It is mainly contested that notice under section 148 of the Income Tax Act was issued beyond the limitation period as prescribed under the erstwhile

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