S. 148A: Reassessment – Conducting inquiry, providing opportunity before issue of notice – Where the alleged escaped income is below the prescribed monetary threshold of Rs.50 lakhs, the period of limitation as stipulated under Clause (a) of Sub-section (1) of Section 149 of the 1961 Act would be applicable- The period prescribed under the said Clause is three (03) years from the end of the relevant assessment year – Reopening notices dated 30.6.2021 and 28.06.2021 issued were held to be barred by limitation . [ S. 148 , 148A(b) , 148A(d), 149(1))(a) , Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Act, 2020, S. 3 , Art .142 , 226 ]
Ganesh Dass Khanna v. ITO (2023) 156 taxmann.com 417 (Delhi )( HC)