https://www.taxtmi.com/caselaws?id=236692 Reassessment under sections 147 and 148 was upheld because the recorded reasons and material before the Assessing Officer were sufficient to form a belief that income had escaped assessment. The joint development agreement, read with the irrevocable power of attorney, was treated as a transfer under section 2(47) because it conferred effective control, possessory rights, and powers to deal with the property, so capital gains arose in the year of the agreement under sections 45 and 48. The later non-completion of construction did not affect accrual of consideration. Relief under section 54F and the contention that taxation belonged only in the society's hands were rejected. en-us Wed, 28 Aug 2013 00:00:00 +0530 Thu, 05 Sep 2013 11:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=236692 Reassessment under sections 147 and 148 was upheld because the recorded reasons and material before the Assessing Officer were sufficient to form a belief that income had escaped assessment. The joint development agreement, read with the irrevocable power of attorney, was treated as a transfer under section 2(47) because it conferred effective control, possessory rights, and powers to deal with the property, so capital gains arose in the year of the agreement under sections 45 and 48. The later non-completion of construction did not affect accrual of consideration. Relief under section 54F and the contention that taxation belonged only in the society's hands were rejected. Case-Laws Income Tax Wed, 28 Aug 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=236692