Topic

Section 149 limitation

2 articlesLatest August 2026
Section 149(1)(a) bars reopening where §148 notice issued after 3 years and escaped income < Rs 50 Lakh - bogus political donation deduction denied | ITAT Jaipur
|Income Tax Appellate Tribunal

Section 149(1)(a) bars reopening where §148 notice issued after 3 years and escaped income < Rs 50 Lakh - bogus political donation deduction denied | ITAT Jaipur

The tribunal held that a section 148 notice dated 12-April-2023 was time-barred under section 149(1)(a) because the income escaping assessment was below Rs 50 lakh, and therefore quashed the assessment disallowing the claimed deduction under 80GGC for a bogus political donation. The ruling underscores that reopening notices beyond three years are invalid when the escaped income does not exceed the Rs 50 lakh threshold.

Section 148 notice barred by Section 149(1)(b) limitation; Rs 20.04 cr share-capital addition quashed | Income-Tax reassessment : ITAT (Kolkata)
Case Law Analysis
|Income Tax Appellate Tribunal

Section 148 notice barred by Section 149(1)(b) limitation; Rs 20.04 cr share-capital addition quashed | Income-Tax reassessment : ITAT (Kolkata)

ITAT Kolkata ruled the Section 148 reassessment notice for AY 2015-16 was barred by Section 149(1)(b) and set aside the ₹20.04 crore share-capital addition treated as unexplained cash credit. The decision protects taxpayers from reassessment notices served outside the statutory limitation period.