Reassessment Quashed: Income Below ₹50 Lakh Threshold Bars Extended Limitation
Hyderabad ITAT Rules on Jurisdictional Limit under Section 149(1)(b) Post-Lapse of Three Years. A crucial ruling from the Hyderabad Income Tax Appellate Tribunal (ITAT) has reinforced the importance of the monetary threshold for issuing reopening notices under Section 148 after the standard three-year period has lapsed. The Tribunal held that if the income that has escaped assessment is substantially less than the ₹50 lakh limit, the Assessing Officer (AO) is divested of jurisdiction to invoke the extended time limit 180 taxmann.com 709 (Hyderabad - Trib.)]. The Facts of the ₹19.31 Lakh Dispute The case pertains to Assessment Year (AY) 2016-17. The assessee had: Traded in shares and claimed Long Term Capital Gains (LTCG) as exempt under Section 10(38) . The AO subsequently issued a reopening notice on July 30, 2022, alleging that the assessee was a beneficiary...