https://www.taxtmi.com/caselaws?id=757906 The Gujarat HC ruled in favor of the assessee regarding validity of reopening assessment under Section 148. The petitioner had offered entire sale consideration from land sale under business income, which was subjected to detailed scrutiny in original assessment under Section 143(3). The AO had raised questions, received detailed replies with documents, and framed assessment accordingly. The court held that Section 50C does not apply to sale of stock-in-trade as it is not a capital asset. The reopening notice issued beyond four years based on applicability of Section 50C constituted mere change of opinion, making the notice untenable. en-us Fri, 23 Aug 2024 00:00:00 +0530 Wed, 04 Sep 2024 08:20:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757906 The Gujarat HC ruled in favor of the assessee regarding validity of reopening assessment under Section 148. The petitioner had offered entire sale consideration from land sale under business income, which was subjected to detailed scrutiny in original assessment under Section 143(3). The AO had raised questions, received detailed replies with documents, and framed assessment accordingly. The court held that Section 50C does not apply to sale of stock-in-trade as it is not a capital asset. The reopening notice issued beyond four years based on applicability of Section 50C constituted mere change of opinion, making the notice untenable. Case-Laws Income Tax Fri, 23 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757906