The assessee, a partnership firm, was reopened for A.Y. 2014-15 on the basis of information emanating from search proceedings in Rajendra Jain Group alleging bogus purchase entries from two concerns aggregating to Rs. 3.02 crore. The reassessment notice under section 148 was issued beyond three years from the end of the relevant assessment year. The assessee contended that for A.Y. 2014-15 the applicable law was section 149(1)(b) as substituted by the Finance Act, 2021, under which reopening beyond three years was permissible only where the Assessing Officer possessed material showing escapement of income represented in the form of an “asset” of Rs. 50 lakh or more. The Tribunal held that alleged bogus purchases are profit and loss/revenue items and cannot be regarded as an “asset” unless such purchases result in a specific asset reflected in the balance sheet, which was not the Revenue’s case. Following IDFC Ltd. v. DCIT  v. DCIT [2023] 155 taxmann.com 602/459 ITR 169 (Mad( HC)  and Hexaware Technologies Ltd. v. ACIT [2024] 162 taxmann.com 225 (Bom.HC), the Tribunal held that the mandatory jurisdictional condition under section 149(1)(b) was not satisfied; therefore, the notice issued under section 148 was invalid, the reassessment proceedings were bad in law, and the assessment framed thereon could not survive. As the reassessment itself was quashed, the addition on account of alleged bogus purchases stood deleted and other issues on merits were rendered academic.  ( ITA No. 6613/Mum/2025,dt.  06-03-2026.)  (A.Y. 2014-15