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Reassessment is not a change of opinion where original scrutiny...
Agricultural-land reinvestment qualifies when transfer consideration precedes replacement purchase, while unexamined claims may be reassessed on escaped-income grounds.
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Reassessment is not a change of opinion where original scrutiny records contained relevant material but the agricultural-land reinvestment claim and actual sales commission were never examined. Agricultural-land reinvestment may qualify for deduction where an agreement to sell provides for instalment consideration and proportionate possession, and replacement land is acquired from consideration received before execution of the final sale deed. A differential commission addition is unwarranted where Form 26AS and the profit and loss account reconcile the actual commission received, including its treatment through evaporation loss.
Reassessment is not a change of opinion where original scrutiny records contained relevant material but the agricultural-land reinvestment claim and actual sales commission were never examined. Agricultural-land reinvestment may qualify for deduction where an agreement to sell provides for instalment consideration and proportionate possession, and replacement land is acquired from consideration received before execution of the final sale deed. A differential commission addition is unwarranted where Form 26AS and the profit and loss account reconcile the actual commission received, including its treatment through evaporation loss.
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