🔹 Reassessment Invalid under Section 148/149(1)(b)
In the instant case, the Tribunal quashed the reassessment proceedings since the alleged escaped income was below ₹50 lakh. It reaffirmed that the extended time limit under section 149(1)(b) cannot apply unless the threshold is crossed – a welcome interpretation aligning with the Finance Act, 2021 and judicial precedents (Ashish Agarwal, Sumit Agrawal).
The notice under section 148 of the Act is unsustainable and lacks jurisdiction. Ex–consequenti,the assessment order is quashed and the entire addition is directed to be deleted.