Reassessment barred by Limitation

The Tribunal observed that the extended limitation period can be invoked only where escaped income represented in specified forms amounts to ₹50 lakh or more.

Since this statutory threshold was not met, the approval granted under Section 151 was held to be invalid, rendering the reassessment unsustainable in law.

The ruling reinforces that reassessment proceedings under the post-2021 regime must strictly comply with the safeguards and monetary thresholds prescribed under Section 149 of the Income-tax Act.