Purposive interpretation of residential house exemption: unregistered purchase agreement alone does not defeat relief, but investment must be verified...
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HC allowed the petition, invalidating the reassessment notice. The court determined that the Assessing Officer lacked sufficient material to demonstrate income escaping assessment exceeding Rs. 50 lacs in AY 2013-14. The notice was found to be beyond the prescribed limitation period under Section 149(1)(a) and did not satisfy conditions under Section 149(1)(b). The court specifically noted no evidence of undisclosed transactions or income, rendering the reassessment notice procedurally and substantively unsustainable. Consequently, the impugned order and notice were set aside, providing relief to the assessee.
HC allowed the petition, invalidating the reassessment notice. The court determined that the Assessing Officer lacked sufficient material to demonstrate income escaping assessment exceeding Rs. 50 lacs in AY 2013-14. The notice was found to be beyond the prescribed limitation period under Section 149(1)(a) and did not satisfy conditions under Section 149(1)(b). The court specifically noted no evidence of undisclosed transactions or income, rendering the reassessment notice procedurally and substantively unsustainable. Consequently, the impugned order and notice were set aside, providing relief to the assessee.
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