HC quashed reassessment notice u/s 148 and assessment order u/s...

HC quashed reassessment notice u/s 148 and assessment order u/s 147 read with s 144B where AO denied capital gains deduction u/s 54. AO disallowed deduction solely because legal heirs deposited sale proceeds after original assessee's death, despite proper disclosure in return and valid investment claim of Rs 3 crores against capital gains liability. Court held AO's hyper-technical approach regarding timing of deposit by legal heirs after assessee's demise provided no valid ground for reopening assessment under s 147, particularly when no tangible information existed that income had escaped assessment and legal heirs had properly disclosed property sale and claimed legitimate deduction.

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