https://www.taxtmi.com/caselaws?id=359499 The Tribunal held that the re-opening of proceedings under Section 148 of the Income Tax Act was without jurisdiction, as it constituted a change of opinion without new reason to believe income had escaped assessment. The re-opening lacked proper application of mind and was based on borrowed satisfaction from an audit objection. Despite the appellant's argument citing a recent decision of the Bombay High Court, both the CIT(A) and the Tribunal found the re-opening invalid, leading to the dismissal of the appeal. The tax treatment of profit from property sale was not extensively addressed, with the focus on the re-opening notice's validity. The High Court ultimately dismissed the appeal without costs. en-us Tue, 24 Apr 2018 00:00:00 +0530 Tue, 01 May 2018 06:25:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=359499 The Tribunal held that the re-opening of proceedings under Section 148 of the Income Tax Act was without jurisdiction, as it constituted a change of opinion without new reason to believe income had escaped assessment. The re-opening lacked proper application of mind and was based on borrowed satisfaction from an audit objection. Despite the appellant's argument citing a recent decision of the Bombay High Court, both the CIT(A) and the Tribunal found the re-opening invalid, leading to the dismissal of the appeal. The tax treatment of profit from property sale was not extensively addressed, with the focus on the re-opening notice's validity. The High Court ultimately dismissed the appeal without costs. Case-Laws Income Tax Tue, 24 Apr 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=359499