Reopening Quashed – Incorrect Facts Cannot Extend Limitation Beyond 3 Years

Adilakshmi Vangala Vs ITO (ITAT Hyderabad) The Hyderabad ITAT quashed reassessment proceedings holding that incorrect or non-existent facts cannot be used to extend limitation under Section 149. The Assessing Officer reopened the case alleging cash deposits exceeding ₹50 lakh based on multiple transactions. However, upon verification , the Tribunal found that actual deposits were only ₹38.10 lakh, with other transactions being unrelated or wrongly considered. Since the escaped income was below ₹50 lakh, the applicable limitation under Section 149(1)(b) was 3 years, whereas the notice und...