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The ITAT held that the reopening of assessment under section 147/148 for AY 2012-13 was unjustified as the original assessment under section 143(3) was completed with full disclosure of relevant facts, including the slump sale agreement and escrow amount. The reassessment lacked new or tangible material, constituting an impermissible change of opinion. Regarding the addition of long-term capital gains, the tribunal agreed that the escrow amount was contingent and not receivable in the relevant assessment year, as the assessee did not have an enforceable right to it until conditions were fulfilled in a subsequent year. Consequently, the addition made by the AO was invalid. The appeal filed by the revenue was dismissed.
The ITAT held that the reopening of assessment under section 147/148 for AY 2012-13 was unjustified as the original assessment under section 143(3) was completed with full disclosure of relevant facts, including the slump sale agreement and escrow amount. The reassessment lacked new or tangible material, constituting an impermissible change of opinion. Regarding the addition of long-term capital gains, the tribunal agreed that the escrow amount was contingent and not receivable in the relevant assessment year, as the assessee did not have an enforceable right to it until conditions were fulfilled in a subsequent year. Consequently, the addition made by the AO was invalid. The appeal filed by the revenue was dismissed.
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