https://www.taxtmi.com/caselaws?id=460039 A statutory corporation engaged in industrial land development and provision of infrastructure for consideration was treated as carrying on trade, commerce or business within the proviso to section 2(15), so exemption under section 11 was denied and Article 289(1) immunity was not available. Reopening under section 147 was upheld because the recorded reasons showed prima facie material that receipts from sale or long-term lease of industrial plots had escaped assessment, and the challenge as a mere change of opinion failed. The question whether lease premium, rent and interest receipts were taxable required fresh examination in light of a later co-ordinate bench ruling that the land was not owned by the assessee, and the matter was remanded for reconsideration after hearing the assessee. en-us Wed, 31 Oct 2018 00:00:00 +0530 Wed, 08 Jan 2025 18:56:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460039 A statutory corporation engaged in industrial land development and provision of infrastructure for consideration was treated as carrying on trade, commerce or business within the proviso to section 2(15), so exemption under section 11 was denied and Article 289(1) immunity was not available. Reopening under section 147 was upheld because the recorded reasons showed prima facie material that receipts from sale or long-term lease of industrial plots had escaped assessment, and the challenge as a mere change of opinion failed. The question whether lease premium, rent and interest receipts were taxable required fresh examination in light of a later co-ordinate bench ruling that the land was not owned by the assessee, and the matter was remanded for reconsideration after hearing the assessee. Case-Laws Income Tax Wed, 31 Oct 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460039