Reopening assessments beyond four years requires nondisclosure of material facts; mere change of opinion or general allegations invalidates reassessme...
Addition under Section 56(2)(vii) was challenged where two land parcels acquired below Stamp Duty Value were treated as stock-in-trade; lower authorities sustained the addition due to the assessee's failure to produce books and purchase-sale records, creating an evidentiary deficit. The tribunal, without deciding the asset classification on merits, set aside the order and remanded the matter to the AO for de novo adjudication, directing examination of books and financial-statement treatment, verification of the applicability of CBDT Circular No. 1/2011 and relevant precedents on the definition of "property", and affording the assessee a reasonable, effective opportunity to be heard.
Addition under Section 56(2)(vii) was challenged where two land parcels acquired below Stamp Duty Value were treated as stock-in-trade; lower authorities sustained the addition due to the assessee's failure to produce books and purchase-sale records, creating an evidentiary deficit. The tribunal, without deciding the asset classification on merits, set aside the order and remanded the matter to the AO for de novo adjudication, directing examination of books and financial-statement treatment, verification of the applicability of CBDT Circular No. 1/2011 and relevant precedents on the definition of "property", and affording the assessee a reasonable, effective opportunity to be heard.
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