https://www.taxtmi.com/caselaws?id=446600 Delhi HC quashed reassessment proceedings under Section 147 against a company for land sale transaction. The court held that the AO erroneously applied Section 50C when land was stock-in-trade, not capital asset. The reassessment was initiated after four years without alleging non-disclosure of material facts, constituting mere change of opinion. The PCIT's approval was mechanical without proper application of mind. The transaction was not sham as documents were genuine and previously scrutinized during original assessment. The court emphasized that reopening concluded assessments requires careful examination by senior officers, which was lacking here. en-us Mon, 04 Dec 2023 00:00:00 +0530 Wed, 18 Feb 2026 16:30:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446600 Delhi HC quashed reassessment proceedings under Section 147 against a company for land sale transaction. The court held that the AO erroneously applied Section 50C when land was stock-in-trade, not capital asset. The reassessment was initiated after four years without alleging non-disclosure of material facts, constituting mere change of opinion. The PCIT's approval was mechanical without proper application of mind. The transaction was not sham as documents were genuine and previously scrutinized during original assessment. The court emphasized that reopening concluded assessments requires careful examination by senior officers, which was lacking here. Case-Laws Income Tax Mon, 04 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446600