Tribunal held that the Assessing Officer found that the assessee had not disclosed sale consideration of immovable property of Rs. 45,00,000 in his return, the income escaping assessment under the head capital gains was certainly more than Rs. one lakh and, therefore, notice issued under s. 148 within six years from the end of the relevant asst. yr. 2015-16 fell within the time-limit prescribed under s. 149 of the old regime. Tribunal also held that the notice issued under s, 148 through the electronic platform on the assessee’s email ID available with the Department and the assessee having participated in the assessment proceedings, which were carried out in a faceless manner under S. 144B, there was no illegality or invalidity in the service of notice (AY. 2015-16)
Alauddin v. ITO (2025) 236 TTJ 497 (Agra)(Trib)
S. 149: Reassessment-Time limit for notice-Income escaping assessment was certainly more than Rs. one lakh. Notice dt. 31st March, 2021, issued under s. 148 within six years from the end of the asst. yr. 2015-16, falls within the time-limit of the old regime.-Notice through electronic platform on assessee’s email-ID-No illegality or invalidity either in the notice under s. 148 r/w s. 142(1) or at any stage of the assessment proceedings.[S.143(2), 144B,147, 148, 151]
Leave a Reply