https://www.taxtmi.com/caselaws?id=756635 The ITAT Hyderabad quashed the reopening of assessment under section 147, ruling that Revenue Audit's interpretation regarding applicability of section 50C to a sale transaction did not constitute "information" required for reopening. The tribunal held that audit department's legal interpretation cannot serve as basis for reopening proceedings, distinguishing it from information about law from formal sources. Additionally, the tribunal found section 50C inapplicable to property sold after conversion from capital asset to stock-in-trade, citing binding precedents. The assessment reopening was deemed based on mere suspicion rather than reason to believe income escaped taxation. Appeal decided in favor of assessee. en-us Fri, 03 May 2024 00:00:00 +0530 Tue, 06 Aug 2024 14:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756635 The ITAT Hyderabad quashed the reopening of assessment under section 147, ruling that Revenue Audit's interpretation regarding applicability of section 50C to a sale transaction did not constitute "information" required for reopening. The tribunal held that audit department's legal interpretation cannot serve as basis for reopening proceedings, distinguishing it from information about law from formal sources. Additionally, the tribunal found section 50C inapplicable to property sold after conversion from capital asset to stock-in-trade, citing binding precedents. The assessment reopening was deemed based on mere suspicion rather than reason to believe income escaped taxation. Appeal decided in favor of assessee. Case-Laws Income Tax Fri, 03 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756635