https://www.taxtmi.com/caselaws?id=402760 Failure to furnish the recorded reasons for reopening when demanded during reassessment vitiated the reassessment, so the reopening challenge succeeded. The later memorandum arrangement was treated as having substituted and extinguished the earlier development agreement by novation, and the statutory requirements for part performance were not satisfied; therefore, no transfer arose under section 2(47)(v) in the relevant year and capital gains could not be taxed then. As the transfer itself was not established, the related capital gains computation and consequential interest adjustments also lacked a legal basis. en-us Fri, 14 Aug 2020 00:00:00 +0530 Tue, 12 Jan 2021 13:32:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=402760 Failure to furnish the recorded reasons for reopening when demanded during reassessment vitiated the reassessment, so the reopening challenge succeeded. The later memorandum arrangement was treated as having substituted and extinguished the earlier development agreement by novation, and the statutory requirements for part performance were not satisfied; therefore, no transfer arose under section 2(47)(v) in the relevant year and capital gains could not be taxed then. As the transfer itself was not established, the related capital gains computation and consequential interest adjustments also lacked a legal basis. Case-Laws Income Tax Fri, 14 Aug 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=402760