ITAT allowed the assessee's appeal and quashed the reassessment...

ITAT allowed the assessee's appeal and quashed the reassessment order passed u/s 147 r.w.s. 144B. The AO had reopened the assessment solely on the belief that income had escaped assessment by non-application of s.50C (capital gains on transfer of land/building). However, in the reassessment, no addition was made under s.50C; instead, the AO invoked s.43CA (business income on transfer of land/building held as stock-in-trade), which was never part of the recorded reasons. Holding this change impermissible, ITAT declared the reassessment invalid and set it aside.