https://www.taxtmi.com/caselaws?id=442815 Reopening beyond four years is impermissible where the issue was already raised and to in the original scrutiny assessment, because a later notice based on the same material amounts to a change of opinion unless there was failure to fully and truly disclose material facts. The article also notes that a development agreement does not amount to a deemed transfer for capital gains unless it confers possession in the manner required by section 53A of the Transfer of Property Act. On the stated facts, the reassessment notice was unsustainable and the development arrangement was not a transfer under section 2(47)(v). en-us Mon, 04 Sep 2023 00:00:00 +0530 Mon, 04 Dec 2023 17:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=442815 Reopening beyond four years is impermissible where the issue was already raised and to in the original scrutiny assessment, because a later notice based on the same material amounts to a change of opinion unless there was failure to fully and truly disclose material facts. The article also notes that a development agreement does not amount to a deemed transfer for capital gains unless it confers possession in the manner required by section 53A of the Transfer of Property Act. On the stated facts, the reassessment notice was unsustainable and the development arrangement was not a transfer under section 2(47)(v). Case-Laws Income Tax Mon, 04 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=442815