https://www.taxtmi.com/caselaws?id=448998 The ITAT Ahmedabad ruled in favor of the assessee regarding the validity of reopening assessment under Section 147. The Department argued that an HUF cannot claim Section 54 exemption when property is purchased in an individual's name rather than the HUF's name. The Tribunal held that since the Section 54 exemption claim was already considered and decided in the original assessment under Section 143(3), and the CIT(A)'s order dated 03.08.2015 remained uncontested, reopening on the same issue constituted a mere change of opinion, which is impermissible under the Supreme Court precedent in CIT vs. Kelvinator of India Limited. en-us Wed, 31 Jan 2024 00:00:00 +0530 Sat, 03 Feb 2024 08:25:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448998 The ITAT Ahmedabad ruled in favor of the assessee regarding the validity of reopening assessment under Section 147. The Department argued that an HUF cannot claim Section 54 exemption when property is purchased in an individual's name rather than the HUF's name. The Tribunal held that since the Section 54 exemption claim was already considered and decided in the original assessment under Section 143(3), and the CIT(A)'s order dated 03.08.2015 remained uncontested, reopening on the same issue constituted a mere change of opinion, which is impermissible under the Supreme Court precedent in CIT vs. Kelvinator of India Limited. Case-Laws Income Tax Wed, 31 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448998