2019 (7) TMI 405 - SCH - Income Tax

SC dismisses SLP for low tax effect, leaves question of law open. Interlocutory applications disposed, delay condoned.

The SC dismissed the special leave petition due to low tax effect, but left the question of law open. Pending interlocutory applications were disposed of, ... Reopening of assessment beyond 4 years u/s 147 - computation of Capital Gain - sale of four agricultural lands - revenue contended that, assessee had no agriculture land for more than two years before transfer and there was no evidence that the land was put to agriculture use in the last two years before sale - HC held there is nothing on record to suggest that there was any failure on the part of the assessee to disclose truly and fully all material facts necessary for assessment - HELD THAT:- In view of the low tax effect, the instant special leave petition is dismissed. However, the question of law is left open. The Supreme Court dismissed the special leave petition due to low tax effect, but left the question of law open. Pending interlocutory applications were disposed of. Delay was condoned.