|Income Tax Appellate Tribunal
Section 148 | Reassessment Valid Only When Escaped Income Is An Asset Under Sec 153A Explanation 2 : ITAT Delhi
The ITAT Delhi held that reassessment under section 148 is valid only if the escaped income is an asset as per Explanation 2 to section 153A, noting that unsecured loans received by the assessee qualify as such assets and that liability-side entries do not defeat the extended limitation when the escaped amount exceeds ₹50 lakh.