Tax Notices Invalidated: Income Aggregation Across Multiple Years Deemed Improper and Violating Procedural Limitations of Section 148

HC held that the Assessing Officer (AO) erroneously issued notices under Section 148 by aggregating alleged escaped income across multiple financial years 2016-17, 2017-18, and 2018-19. The court determined that the threshold limit of Rs. 50 lakhs cannot be calculated by cumulating income from different assessment years. The notices were time-barred under Section 149(1) as there was no singular event spanning multiple years. Consequently, the HC set aside the impugned notices and subsequent proceedings, finding that the AO's approach of combining escaped income from different years was impermissible under tax law. .....

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