#Income Tax Act Section 147

ITAT Surat holds that reassessment proceedings under Section 147 of the Income Tax Act beyond four years from the end of the assessment year are invalid unless new tangible material justifying escapement of income is discovered. The ruling quashes reassessment orders for AY 2011-12 and 2014-15, reinforcing the limitation period for tax authorities and protecting assessees from arbitrary reopening of cases.

The ITAT Delhi has ruled that the Income Tax Department cannot reopen an assessment solely on the basis of unreported cash deposits if no addition is made against those deposits in the original assessment. This sets a critical precedent: mere non-filing of return coupled with large cash inflows is insufficient grounds for reopening - the revenue must demonstrate a tangible income addition. Taxpayers and practitioners now have clear protection against speculative reassessments based on deposit volume alone.

ITAT Ahmedabad rules that reassessment notices u/s 148 issued beyond the limitation period for escaped income below ₹50 lakh are invalid, setting aside the assessment order and remanding the case for fresh consideration. The tribunal emphasized procedural fairness, requiring the AO to provide recorded reasons and allow the assessee to substantiate capital gains computation.