https://www.taxtmi.com/caselaws?id=450951 A reassessment notice under section 148 cannot be sustained where the impugned transfer is an admitted gift of shares without consideration and the statutory scheme does not bring such transfer within capital gains tax. Section 45 applies to transfers yielding profits or gains, section 48 computes gains with reference to consideration received or accruing, and section 47(iii) excludes gifts from section 45. On those provisions, and despite the return having been processed under section 143(1), there was no tangible material to form a valid belief that taxable income had escaped assessment. en-us Fri, 08 Mar 2024 00:00:00 +0530 Wed, 09 Jul 2025 17:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450951 A reassessment notice under section 148 cannot be sustained where the impugned transfer is an admitted gift of shares without consideration and the statutory scheme does not bring such transfer within capital gains tax. Section 45 applies to transfers yielding profits or gains, section 48 computes gains with reference to consideration received or accruing, and section 47(iii) excludes gifts from section 45. On those provisions, and despite the return having been processed under section 143(1), there was no tangible material to form a valid belief that taxable income had escaped assessment. Case-Laws Income Tax Fri, 08 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450951