Transfer fee demand on leasehold land transfer by statutory corporation challenged; petition dismissed for fact suppression and inapplicable IBC Secti...
Reopening of assessment was challenged because the stated grounds-an alleged clerical mistake in inventory computations and unexplained cash deposits-no longer survive: the inventory-based addition has since been deleted by the ITAT and the Revenue does not dispute that deletion, and the cash deposits were specifically queried and satisfactorily explained with the cash book produced during original scrutiny, leading the AO then to make no addition. The article concludes that reassessment here amounts to a mere change of opinion and is therefore not justified.
Reopening of assessment was challenged because the stated grounds-an alleged clerical mistake in inventory computations and unexplained cash deposits-no longer survive: the inventory-based addition has since been deleted by the ITAT and the Revenue does not dispute that deletion, and the cash deposits were specifically queried and satisfactorily explained with the cash book produced during original scrutiny, leading the AO then to make no addition. The article concludes that reassessment here amounts to a mere change of opinion and is therefore not justified.
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