Section 149(1)(b) Conditions Unmet: Reopening and Adhoc Profit Addition Quashed – ITAT Kolkata

Rakhi Mondal Vs Assessment Unit (ITAT Kolkata) Reopening Beyond 3 Years Quashed – Conditions u/s 149(1)(b) Not Satisfied – Adhoc Profit Estimation Without Rejecting Books Invalid – ITAT Kolkata ITAT Kolkata quashed reassessment holding that notice u/s 148 issued beyond 3 years was invalid as mandatory conditions of Sec 149(1)(b) were not fulfilled and AO failed to show escaped income represented as specified asset/entry exceeding ₹50 lakh. Tribunal further held that CIT(A)’s estimation of 15% profit on turnover was unsustainable since books were never rejected u/s 145(3), and adhoc e...