https://www.taxtmi.com/caselaws?id=360337 Reassessment under section 147 requires recorded reasons that are duly signed, as the signing of reasons and valid notice under section 148 are treated as jurisdictional requirements rather than mere technicalities. The note also states that reopening fails where the foundational belief of escapement is factually incorrect: if the land sold lies beyond municipal limits, it is not a capital asset under section 2(14), and no valid belief of capital gains escapement can arise. On those facts, the reassessment is unsupported by the recorded reasons and is liable to be quashed. en-us Fri, 11 May 2018 00:00:00 +0530 Tue, 15 May 2018 07:14:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=360337 Reassessment under section 147 requires recorded reasons that are duly signed, as the signing of reasons and valid notice under section 148 are treated as jurisdictional requirements rather than mere technicalities. The note also states that reopening fails where the foundational belief of escapement is factually incorrect: if the land sold lies beyond municipal limits, it is not a capital asset under section 2(14), and no valid belief of capital gains escapement can arise. On those facts, the reassessment is unsupported by the recorded reasons and is liable to be quashed. Case-Laws Income Tax Fri, 11 May 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=360337