https://www.taxtmi.com/caselaws?id=343035 A reassessment under section 147 was held unsustainable where the recorded reasons wrongly assumed that execution of a power of attorney on 15.12.2006 amounted to a completed sale. The assessee had not executed an agreement of sale, had not transferred possession, and the conditions for part performance under section 53A of the Transfer of Property Act were not met, so section 2(47)(v) could not be invoked to treat a transfer as having occurred in assessment year 2007-08. Because the reopening rested on an erroneous factual premise, jurisdiction failed and the reassessment notice and order were quashed. en-us Fri, 17 Feb 2017 00:00:00 +0530 Wed, 02 Aug 2017 12:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=343035 A reassessment under section 147 was held unsustainable where the recorded reasons wrongly assumed that execution of a power of attorney on 15.12.2006 amounted to a completed sale. The assessee had not executed an agreement of sale, had not transferred possession, and the conditions for part performance under section 53A of the Transfer of Property Act were not met, so section 2(47)(v) could not be invoked to treat a transfer as having occurred in assessment year 2007-08. Because the reopening rested on an erroneous factual premise, jurisdiction failed and the reassessment notice and order were quashed. Case-Laws Income Tax Fri, 17 Feb 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=343035