https://www.taxtmi.com/caselaws?id=384513 The Tribunal accepted the explanation for delayed filing and treated the appeals as within time under section 253(3). On merits, it upheld reassessment under section 147 because the original assessment rested on wrong facts and the reopening was not a mere change of opinion. The assessee failed to prove that the land qualified for agricultural land exemption under section 2(14)(iii)(b), so the exemption claim was rejected, and the deduction claimed under section 24 was also sustained in disallowance. The penalties were likewise upheld because the cash receipt was treated as a loan or deposit in breach of section 269SS and the cash repayment attracted section 269T, with no evidence sufficient to rebut those findings. en-us Fri, 09 Aug 2019 00:00:00 +0530 Fri, 16 Aug 2019 07:50:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=384513 The Tribunal accepted the explanation for delayed filing and treated the appeals as within time under section 253(3). On merits, it upheld reassessment under section 147 because the original assessment rested on wrong facts and the reopening was not a mere change of opinion. The assessee failed to prove that the land qualified for agricultural land exemption under section 2(14)(iii)(b), so the exemption claim was rejected, and the deduction claimed under section 24 was also sustained in disallowance. The penalties were likewise upheld because the cash receipt was treated as a loan or deposit in breach of section 269SS and the cash repayment attracted section 269T, with no evidence sufficient to rebut those findings. Case-Laws Income Tax Fri, 09 Aug 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=384513