https://www.taxtmi.com/caselaws?id=766698 Reassessment under sections 147 and 148 failed where the sanction under section 151(2) showed no real application of mind to the recorded reasons, so the reopening was without jurisdiction and the reassessment was invalid. The alleged addition for sale consideration also failed because the record did not establish a transfer of the land in the relevant assessment year within section 2(47); the agreements and joint venture arrangements did not prove transfer of title or possession, and the Revenue did not discharge its burden of proof. The jurisdictional challenge and the merits challenge both failed, so the assessment additions were not sustained. en-us Thu, 27 Feb 2025 00:00:00 +0530 Mon, 03 Mar 2025 08:22:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766698 Reassessment under sections 147 and 148 failed where the sanction under section 151(2) showed no real application of mind to the recorded reasons, so the reopening was without jurisdiction and the reassessment was invalid. The alleged addition for sale consideration also failed because the record did not establish a transfer of the land in the relevant assessment year within section 2(47); the agreements and joint venture arrangements did not prove transfer of title or possession, and the Revenue did not discharge its burden of proof. The jurisdictional challenge and the merits challenge both failed, so the assessment additions were not sustained. Case-Laws Income Tax Thu, 27 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766698