https://www.taxtmi.com/caselaws?id=10496 Morcellement receipts under a profit-making development scheme are taxable only to the extent of the profit element derived from the scheme; the pre-existing capital value of the landholder's interest cannot be taxed as income. The assessments in question were therefore said to have been made on an overbroad basis because they charged the entire receipts without deducting the underlying value attributable to the land interest. For the extended limitation period, the authority had to establish fraud or wilful neglect with clear primary findings; mere non-disclosure or non-response was insufficient. On that basis, the discussion states that the assessments for 1989/90 and 1990/91 were out of time, and the taxable amount required recalculation on the profit element only. en-us Tue, 28 Sep 2004 00:00:00 +0530 Thu, 16 Jul 2009 17:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=10496 Morcellement receipts under a profit-making development scheme are taxable only to the extent of the profit element derived from the scheme; the pre-existing capital value of the landholder's interest cannot be taxed as income. The assessments in question were therefore said to have been made on an overbroad basis because they charged the entire receipts without deducting the underlying value attributable to the land interest. For the extended limitation period, the authority had to establish fraud or wilful neglect with clear primary findings; mere non-disclosure or non-response was insufficient. On that basis, the discussion states that the assessments for 1989/90 and 1990/91 were out of time, and the taxable amount required recalculation on the profit element only. Case-Laws Income Tax Tue, 28 Sep 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=10496