https://www.taxtmi.com/caselaws?id=791019 Reassessment under section 148 based on an inflated cash-deposit figure was held invalid because the Assessing Officer acted on incorrect facts. The bank statements showed actual cash deposits of only Rs. 19,50,000, so the matter fell within the lower limitation threshold under section 149(1)(b), requiring reopening within three years from the end of the relevant assessment year. As the notice under section 148 was issued beyond that period, it was time-barred, and the consequential order under section 148A(d) also failed because the foundational notice was defective. The reassessment proceedings were therefore set aside in favour of the assessee. en-us Thu, 23 Apr 2026 00:00:00 +0530 Sat, 16 May 2026 12:02:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791019 Reassessment under section 148 based on an inflated cash-deposit figure was held invalid because the Assessing Officer acted on incorrect facts. The bank statements showed actual cash deposits of only Rs. 19,50,000, so the matter fell within the lower limitation threshold under section 149(1)(b), requiring reopening within three years from the end of the relevant assessment year. As the notice under section 148 was issued beyond that period, it was time-barred, and the consequential order under section 148A(d) also failed because the foundational notice was defective. The reassessment proceedings were therefore set aside in favour of the assessee. Case-Laws Income Tax Thu, 23 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791019