Allowing the appeal of the assessee the Tribunal held that ,if there is nothing in the recorded reasons to suggest that the income chargeable to tax which has escaped assessment is Rs. one lakh or more, the notice issued u/s 148 of the Act beyond four years of the end of the relevant assessment year is invalid .Followed Mahesh Kumar Gupta v.CIT ( 2014) 363 ITR 300 (All) (HC), Amar Nath Agarwal v.CIT ( 2015) 371 ITR 183 ( All) (HC)(ITA No. 167/Agra/2018, dt. 19.06.2018)(AY. 2007-08)
Usha Agarwal v. ITO (SMC) ( 2018) 194 TTJ 41 (UO) (Agra)(Trib), www.itatonline.org
S.147: Reassessment-After the expiry of four years-If there is nothing in the recorded reasons to suggest that the income chargeable to tax which has escaped assessment is Rs. one lakh or more, the notice issued u/s 148 of the Act beyond four years of the end of the relevant assessment year is invalid [ S.148 ]