https://www.taxtmi.com/caselaws?id=23160 The Supreme Court ruled in favor of the assessee regarding the reopening of assessments for the mentioned years under section 147(a) of the Income-tax Act, 1961. The Court held that the audit note did not constitute valid information under section 147(b), deeming the reassessment as an impermissible change of opinion. However, for the assessment year 1970-71, the Court sided with the Revenue, determining that the lands were not agricultural and the sale proceeds were subject to capital gains tax under section 45 of the Income-tax Act, 1961. No costs were awarded in the judgment. en-us Tue, 20 Dec 1988 00:00:00 +0530 Thu, 17 Dec 2009 11:38:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=23160 The Supreme Court ruled in favor of the assessee regarding the reopening of assessments for the mentioned years under section 147(a) of the Income-tax Act, 1961. The Court held that the audit note did not constitute valid information under section 147(b), deeming the reassessment as an impermissible change of opinion. However, for the assessment year 1970-71, the Court sided with the Revenue, determining that the lands were not agricultural and the sale proceeds were subject to capital gains tax under section 45 of the Income-tax Act, 1961. No costs were awarded in the judgment. Case-Laws Income Tax Tue, 20 Dec 1988 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=23160