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AO reopened assessment on basis of difference between market value and registration value of property, assuming petitioner was owner. Petitioner argued section 50C inapplicable as not owner, section 43CA not in force that year. HC held AO failed to consider petitioner's objections regarding no escapement of income due to value difference being non-taxable. No information with AO showing direct nexus with escaped income alleged. Petitioner disclosed all material facts, so AO lacked jurisdiction u/s 147 proviso to reopen beyond 4 years. Petition allowed.
AO reopened assessment on basis of difference between market value and registration value of property, assuming petitioner was owner. Petitioner argued section 50C inapplicable as not owner, section 43CA not in force that year. HC held AO failed to consider petitioner's objections regarding no escapement of income due to value difference being non-taxable. No information with AO showing direct nexus with escaped income alleged. Petitioner disclosed all material facts, so AO lacked jurisdiction u/s 147 proviso to reopen beyond 4 years. Petition allowed.
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