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    <title>2019 (10) TMI 1166 - ITAT CHENNAI</title>
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    <description>Reassessment under sections 147 and 148 was treated as valid because the assessee had not filed original returns and the Assessing Officer relied on Investigation Directorate material concerning cash deposits, which was held to be tangible incriminating material; the objection based on lack of recorded satisfaction or change of opinion failed on the facts. The unregistered agreement to sell was accepted as a genuine contemporaneous document reflecting the agreed sale consideration and supporting the existence of on-money, but transfer was held to have crystallised only on the registered sale deeds in the later assessment year. The land was found to be agricultural on revenue records and the Village Administrative Officer&#039;s statement, while eligibility for exemption on the resulting capital gain required fresh factual verification.</description>
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    <pubDate>Mon, 21 Oct 2019 00:00:00 +0530</pubDate>
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      <title>2019 (10) TMI 1166 - ITAT CHENNAI</title>
      <link>https://www.taxtmi.com/caselaws?id=387682</link>
      <description>Reassessment under sections 147 and 148 was treated as valid because the assessee had not filed original returns and the Assessing Officer relied on Investigation Directorate material concerning cash deposits, which was held to be tangible incriminating material; the objection based on lack of recorded satisfaction or change of opinion failed on the facts. The unregistered agreement to sell was accepted as a genuine contemporaneous document reflecting the agreed sale consideration and supporting the existence of on-money, but transfer was held to have crystallised only on the registered sale deeds in the later assessment year. The land was found to be agricultural on revenue records and the Village Administrative Officer&#039;s statement, while eligibility for exemption on the resulting capital gain required fresh factual verification.</description>
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      <pubDate>Mon, 21 Oct 2019 00:00:00 +0530</pubDate>
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