https://www.taxtmi.com/caselaws?id=70014 The case involved the computation of capital gains where the assessee treated land and building as separate assets. The reassessment under section 147, treating the property as a single short-term asset based on CBDT instructions, was challenged. The Tribunal held that the land and building should be treated as separate assets. The reassessment was deemed invalid due to reliance on incorrect legal guidance, without new material facts, constituting a change of opinion. Following legal precedent, the reassessment was annulled, and the appeal was allowed in favor of the assessee. en-us Mon, 28 Oct 1991 00:00:00 +0530 Wed, 13 Apr 2011 14:20:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=70014 The case involved the computation of capital gains where the assessee treated land and building as separate assets. The reassessment under section 147, treating the property as a single short-term asset based on CBDT instructions, was challenged. The Tribunal held that the land and building should be treated as separate assets. The reassessment was deemed invalid due to reliance on incorrect legal guidance, without new material facts, constituting a change of opinion. Following legal precedent, the reassessment was annulled, and the appeal was allowed in favor of the assessee. Case-Laws Income Tax Mon, 28 Oct 1991 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=70014