https://www.taxtmi.com/caselaws?id=766538 Gujarat HC ruled that reopening assessment under section 147 based on agricultural land exemption under section 2(14)(iii)(b) was invalid. The AO had previously considered the exemption claim for land beyond 8 km from municipal limits, consulted higher authorities under section 144A, and made no addition in the original assessment. The court held that recording identical reasons upon record verification constituted mere change of opinion, not valid grounds for reopening. Following CIT vs. Kelvinator precedent, the AO lacked jurisdiction to reopen assessment based solely on opinion change. Decision favored the assessee. en-us Fri, 20 Dec 2024 00:00:00 +0530 Thu, 27 Feb 2025 08:14:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766538 Gujarat HC ruled that reopening assessment under section 147 based on agricultural land exemption under section 2(14)(iii)(b) was invalid. The AO had previously considered the exemption claim for land beyond 8 km from municipal limits, consulted higher authorities under section 144A, and made no addition in the original assessment. The court held that recording identical reasons upon record verification constituted mere change of opinion, not valid grounds for reopening. Following CIT vs. Kelvinator precedent, the AO lacked jurisdiction to reopen assessment based solely on opinion change. Decision favored the assessee. Case-Laws Income Tax Fri, 20 Dec 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766538