https://www.taxtmi.com/caselaws?id=357926 Reassessment under section 147 was valid where the return had only been processed under section 143(1) and survey material later revealed an undisclosed development agreement; it was not a mere change of opinion. A development agreement conferring possession and rights to enter the property amounted to transfer under section 2(47)(v) read with section 53 of the Transfer of Property Act, so capital gains arose in the year of the agreement and section 45(5A) did not apply. The issues of short-term or long-term character and the correct full value of consideration required fresh factual examination and were remitted for reconsideration. en-us Wed, 28 Feb 2018 00:00:00 +0530 Mon, 02 Apr 2018 08:59:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=357926 Reassessment under section 147 was valid where the return had only been processed under section 143(1) and survey material later revealed an undisclosed development agreement; it was not a mere change of opinion. A development agreement conferring possession and rights to enter the property amounted to transfer under section 2(47)(v) read with section 53 of the Transfer of Property Act, so capital gains arose in the year of the agreement and section 45(5A) did not apply. The issues of short-term or long-term character and the correct full value of consideration required fresh factual examination and were remitted for reconsideration. Case-Laws Income Tax Wed, 28 Feb 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=357926