Reassessment on tangible escapement material and symbolic possession under a sale agreement did not prove earlier transfer.

Reassessment can be reopened when the Assessing Officer relies on tangible material indicating escapement of income, such as information from stamp and registration authorities showing a mismatch between declared consideration and guidance value; the jurisdictional challenge failed. Symbolic possession under an agreement of sale did not amount to transfer of physical possession in the earlier year, so the transfer could not be treated as having occurred then. The valuation objection under Section 50C was treated as factual and not fit for interference, especially where remand proceedings were already before the appellate authority.

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Issues: (i) Whether reassessment could be reopened on the basis of information indicating escapement of income. (ii) Whether the property was transferred in an earlier year on the basis of symbolic possession under the agreement of sale, and whether valuation under Section 50C required interference.

Issue (i): Whether reassessment could be reopened on the basis of information indicating escapement of income.

Analysis: The reassessment was founded on material received from the stamp and registration authorities showing a substantial difference between the declared sale consideration and the guidance value. That material was before the Assessing Officer and formed the basis for the belief that income chargeable to tax had escaped assessment. The challenge to jurisdiction therefore did not disclose any substantial question of law.

Conclusion: The reopening of assessment was upheld, in favour of the Revenue.

Issue (ii): Whether the property was transferred in an earlier year on the basis of symbolic possession under the agreement of sale, and whether valuation under Section 50C required interference.

Analysis: The agreement recorded delivery only of symbolic possession. On that basis, it was held that physical possession had not been transferred under the earlier agreement so as to treat the transfer as having taken place in an earlier year. The valuation-related grievance was also treated as factual, and the absence of a reference to the valuation officer was noted in the context of the remand already made to the appellate authority. These matters were held not to give rise to a substantial question of law.

Conclusion: No interference was called for on the possession and valuation issues, in favour of the Revenue.

Final Conclusion: The appeal failed and the dismissal left the reassessment and remand-related findings undisturbed, while valuation contentions under Section 50C remained open before the appellate authority.

Ratio Decidendi: Reassessment is sustainable where the Assessing Officer acts on tangible material leading to a reasoned belief of escapement of income, and symbolic possession under an agreement does not, by itself, establish transfer of physical possession or warrant interference on purely factual valuation questions.

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