04 May 2015
The reassessment can be initiated within the time frame and on satisfaction of the Assessing Officer as detailed in Sections 147 to 153 subject to procedure prescribed in these sections.
If earlier assessment is not under Section 143(3) or under Section 147 then no approval is necessary till four years from the end of the Assessment Year for any Assessing Officer, but beyond four years, approval of JCIT/Addl. CIT would be necessary for both the ITO and ACIT/DCIT herself would need no approval. d) The notice under Section 148 can be issued after four years from the end of the Assessment Year only if: i) The income having escaped assessment is not less than Rs. 1 lac for that Assessment Year. In any case, no notice can be issued after six years from the end of the Assessment Year normally. ii) The only exception is income from “foreign assets” which, when forms the basis of reopening, notice in that case the notice can be issued till end of 16 years from the end of relevant Assessment Year without any monetary limit subject only to approvals as above.
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