https://www.taxtmi.com/caselaws?id=65927 Reopening under section 147(a) must be supported by a reasonable belief based on the law and facts existing when notice is issued; a later Supreme Court ruling cannot retrospectively validate an otherwise unjustified reopening. Land character for capital gains purposes depends on the totality of surrounding facts, including present user, revenue records, prior treatment, and evidence of conversion. Revenue entries showing agricultural description, land revenue payments, and absence of non-agricultural use created a prima facie agricultural character that the Revenue did not rebut. en-us Wed, 16 Sep 1981 00:00:00 +0530 Sat, 19 Feb 2011 13:03:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=65927 Reopening under section 147(a) must be supported by a reasonable belief based on the law and facts existing when notice is issued; a later Supreme Court ruling cannot retrospectively validate an otherwise unjustified reopening. Land character for capital gains purposes depends on the totality of surrounding facts, including present user, revenue records, prior treatment, and evidence of conversion. Revenue entries showing agricultural description, land revenue payments, and absence of non-agricultural use created a prima facie agricultural character that the Revenue did not rebut. Case-Laws Income Tax Wed, 16 Sep 1981 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=65927