Observing that the reassessment proceedings initiated beyond the normal time limit failed to satisfy the mandatory condition that the alleged escaped income represented an ‘asset’ or ‘entry in the books of account,’ the Tribunal held the notice as invalid and without jurisdiction.

Since the appellant had filed all returns on time and there was no evidence of suppression or intent to evade duty, the demand and equal penalty of Rs. 1.81 crore were set aside

Since the appellant had filed all returns on time and there was no evidence of suppression or intent to evade duty, the demand and equal penalty of Rs. 1.81 crore were set aside