₹50 Lakh Threshold Is Mandatory: ITAT Delhi Quashes Reassessment of Foreign Company as Time-Barred

LL Global Inc. Vs ACIT (ITAT Delhi) ₹50 Lakh Threshold Is Mandatory: ITAT Delhi Quashes Reassessment of Foreign Company as Time-Barred Delhi ITAT (Bench ‘D’) quashed the reassessment proceedings initiated u/s 147 r.w.s. 148, holding them to be barred by limitation under the amended law. The Tribunal noted that the notices u/s 148 were issued beyond three years from the end of the relevant assessment years and that the alleged escapement of income was only ₹4.10 lakh and ₹3.18 lakh, far below the ₹50 lakh threshold mandated u/s 149(1)(b). Relying on the Supreme Court decision in Raj...