Section 148%149

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This discussion clarifies the application of Section 148 notices regarding income tax reassessment periods. The key point is whether the Rs 50 lakh threshold for a 10-year reassessment window applies to a single financial year or a combination of years. The consensus is that the Rs 50 lakh limit pertains to income or assets identified within one specific financial year, not a cumulative amount across multiple years.

dsd1986@gmail.com

dsd1986@gmail.com (Querist)
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16 February 2023 Dear experts, i have one query regarding issuance of notice under section 148. IT can only issue notice to 3 years if amount is less than 50 lacs. Now this 50 lacs is for one F.Y. or it can be for combination of multiple F.Y. as well like 10 lacs in one f.y. 20 in another f.y. and remaining 20 in another f.y. thanks in advance.

Dhirajlal Rambhia

Dhirajlal Rambhia (Expert)
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16 February 2023 AO can issue the notice before the end of a three-year period from the end of the relevant assessment year.
However, if the concealed/escaped income exceeds Rs.50 lakh (in the form of assets/expenditures/entries in books; in any single particular year), reassessment can be done up to 10 years from the relevant assessment year.

dsd1986@gmail.com

dsd1986@gmail.com (Querist)
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16 February 2023 Dear sir...really thanks for revert but my query is this 50 lacs should have to be from one f.y. or can it be in multiple f.y. as well..like for one f.y. 10 lacs time limit is expired but we add the 40 lacs from next f.y. it will be 50 lacs wiil the limit here is 3 years or 10 years

Dhirajlal Rambhia

Dhirajlal Rambhia (Expert)
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16 February 2023 The answer is one financial year, but for IT department it can be an asset found out in one year, which you may have created in 3 or 5 years!!!

dsd1986@gmail.com

dsd1986@gmail.com (Querist)
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16 February 2023 Thank you for clarification of the doubt...very clear now...

Dhirajlal Rambhia

Dhirajlal Rambhia (Expert)
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17 February 2023 Most Welcome.

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