Reopening After 3 Years Barred If Escapement Below ₹50L: ITAT Delhi

Sarabjit Singh Bedi Vs DCIT (ITAT Delhi) Reassessment Beyond 3 Years Quashed Where Escapement Below ₹50 Lakh – ITAT Delhi The Delhi Bench of the ITAT quashed the reassessment proceedings for AY 2017-18, holding that the notice issued under section 148 was without jurisdiction as it violated the mandatory conditions of section 149 of the Income-tax Act. The notice was issued on 31.03.2023, i.e. beyond three assessment years from the end of AY 2017-18. The Tribunal noted that for reopening beyond three years (up to ten years), section 149(1)(b) mandates that the alleged income escaping asses...