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With the reassessment proceedings held invalid, additions relating to property valuation and unexplained investment were not examined on merits. The appeal was allowed on legal grounds.
The Tribunal held that a notice issued under section 148 beyond the six-year limitation under the old law is invalid. It clarified that the first proviso to section 149 bars such reopening even under the amended regime.
The Tribunal held that reopening beyond three years requires escaped income in the form of an asset. Since bogus purchases are revenue items, the reassessment was declared invalid.
The tribunal held reopening invalid where actual escaped income was below ₹50 lakh. It clarified that jurisdiction depends on real income, not transaction value.
ITAT remanded the matter where the assessee claimed PAN misuse leading to additions under Sections 68 and 69. It directed AO to verify the police report, holding that relief must be granted if misuse is substantiated.
The Tribunal examined whether reassessment proceedings were valid when initiated beyond the statutory time limit. It held that the notice issued under Section 148 was barred by limitation and invalid. The ruling emphasizes strict adherence to limitation provisions in reassessment cases.
ITAT Mumbai held that reassessment initiated without approval from the correct authority under Section 151 is invalid. Since the reassessment itself was void, the revision order under Section 263 could not survive.
The Tribunal held that reopening beyond three years requires sanction from higher authorities under Section 151(ii). Since approval was obtained only from the PCIT, the reassessment notice was declared invalid.
The tribunal noted discrepancies in the dispatch register used to prove issuance of the notice. Because the records did not inspire confidence, the tribunal held the reassessment notice to be time-barred.
The Tribunal held that a notice under section 148 issued beyond three years requires sanction from PCCIT under section 151(ii). Approval from PCIT was held insufficient, leading to quashing of the reassessment.
