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ITAT Bangalore quashed reassessment for AY 2017-18, holding notice issued on 12-04-2024 time-barred under first proviso to Sec.149(1), despite prior 148A proceedings.
The Court ruled that reopening based solely on an audit objection amounts to change of opinion if the issue was previously examined. Without fresh tangible material, reassessment proceedings are unsustainable.
Kerala High Court held that importer mis-declared semi-dried dates imported by them as fresh dates hence IGST exemption wrongly claimed. Further, importer approached to amend bill of entry only after initiation of proceedings under section 28, accordingly, amendment is not permissible.
The decision clarifies that the monetary threshold under Section 149 applies to actual taxable income, not purchase turnover. As the addition fell below ₹50 lakh, reassessment proceedings were invalid.
The Tribunal held that the fresh notice issued under Section 148 was beyond the surviving limitation period available after applying TOLA and Supreme Court directions. As a result, the reassessment proceedings were declared void ab initio.
ITAT held that approval by the Principal Commissioner was invalid where more than three years had elapsed from the assessment year. Since Section 151(ii) required sanction from PCCIT/CCIT, the reassessment was declared void.
ITAT held that under the amended law, reopening after three years is barred where alleged escaped income is under ₹50 lakh. The notice issued under Section 148 was declared invalid and reassessment proceedings were quashed.
Where more than three years had elapsed, approval from the higher specified authority was compulsory before issuing notice. Failure to obtain such approval vitiated the reassessment proceedings.
Applying Supreme Court precedent, the Tribunal held that no notice could be issued once the six-year period under the old regime had expired. The reassessment order was therefore annulled.
The Tribunal held that reassessment for AY 2015–16 was barred by limitation as the Section 148 notice was issued beyond the permissible period. It ruled that TOLA did not extend the time limit and the proceedings were void ab initio.
