https://www.taxtmi.com/caselaws?id=757977 The Punjab and Haryana HC quashed reassessment proceedings initiated under Section 147, finding the AO lacked valid reasons to believe income had escaped assessment. The court held that the AO improperly changed the basis for reopening from unexplained capital gains to adventure in nature of business without evidence or proper show cause notice. The petitioner had purchased agricultural land beyond municipal limits and disclosed the transaction in original returns. The ITO Intelligence report supported the assessee's position that the land was agricultural and outside Section 2(14)(iii) scope. The court found the reassessment was a colourable exercise of power constituting review rather than reassessment, making the proceedings illegal and unsustainable. en-us Mon, 02 Sep 2024 00:00:00 +0530 Tue, 10 Jun 2025 14:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757977 The Punjab and Haryana HC quashed reassessment proceedings initiated under Section 147, finding the AO lacked valid reasons to believe income had escaped assessment. The court held that the AO improperly changed the basis for reopening from unexplained capital gains to adventure in nature of business without evidence or proper show cause notice. The petitioner had purchased agricultural land beyond municipal limits and disclosed the transaction in original returns. The ITO Intelligence report supported the assessee's position that the land was agricultural and outside Section 2(14)(iii) scope. The court found the reassessment was a colourable exercise of power constituting review rather than reassessment, making the proceedings illegal and unsustainable. Case-Laws Income Tax Mon, 02 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757977