https://www.taxtmi.com/caselaws?id=309023 The article examines whether exemption under Section 54B of the Income-tax Act could properly be allowed and whether reopening under Section 148 was sustainable where the Revenue relied on an audit objection and the assessee invoked the principle that a mere change of opinion cannot justify reassessment. It also notes the dispute over whether the land retained its agricultural character and the possible relevance of proceedings under the Urban Land (Ceiling and Regulation) Act, 1976. No final merits determination was recorded; the matter was kept for further consideration, with interim directions for completion of assessment and protection against recovery. en-us Mon, 10 Mar 2014 00:00:00 +0530 Mon, 07 Aug 2023 21:34:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=309023 The article examines whether exemption under Section 54B of the Income-tax Act could properly be allowed and whether reopening under Section 148 was sustainable where the Revenue relied on an audit objection and the assessee invoked the principle that a mere change of opinion cannot justify reassessment. It also notes the dispute over whether the land retained its agricultural character and the possible relevance of proceedings under the Urban Land (Ceiling and Regulation) Act, 1976. No final merits determination was recorded; the matter was kept for further consideration, with interim directions for completion of assessment and protection against recovery. Case-Laws Income Tax Mon, 10 Mar 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=309023