DATTATRAY VITHOBA SAWANT,KALYAN vs. INCOME TAX OFFICER, WD-42(2)(2), MUMBAI
In the result, the appeal filed by the assessee stands allowed
ITA 6081/MUM/2025[2017-18]Status: DisposedITAT Mumbai13 Feb 2026AY 2017-18
Bench: Smt. Beena Pillai ()
Section 10(14)Section 133ASection 142(1)Section 148Section 148ASection 151Section 151ASection 3Section 80CSection 80G
income escaping assessment is less than ₹50,00,000/-, no reassessment notice can be issued after the expiry of three years, as per section 151(1)(b) of the Act.
5.3.1. In the present facts and circumstances of the case, the income alleged to have escaped assessment ... notice issued under the new regime is beyond the period of three years. Accordingly, as per section 151(1)(b) of the Act, the notice issued on 06/07/2022 is bad in law.
5.4. Even otherwise, the appropriate authority who could sanction the said notice, issued beyond a period of three