ITAT Cancels Reopening for AY 2015–16 as Income Was Below ₹50 Lakh and Notice Issued Beyond 3-Year Limit
The Tribunal held that the reassessment notice under Section 148 issued on 31.03.2022 was invalid since the income alleged to have escaped assessment (₹33.70 lakhs) was below the ₹50 lakh threshold required for reopening beyond 3 years under the amended Section 149. The land sold was rural agricultural land jointly held, and the assessee’s share was only ₹31.51 lakhs. The assessment was declared void ab initio, and the appeal was allowed on legal grounds without going into merits.
The copy of the order is as under:
