https://www.taxtmi.com/caselaws?id=766965 ITAT Jaipur upheld CIT(A)'s decision quashing reassessment proceedings initiated after 4 years based on audit objection. The tribunal held that reopening was impermissible as it constituted mere change of opinion on same material facts previously disclosed by assessee during original assessment. Revenue failed to establish non-disclosure of material facts. Additionally, ITAT ruled that change of land use from cinema hall to commercial complex through development agreement did not constitute conversion of capital asset to stock-in-trade under Section 45(2), as assessee was not in real estate business and consistently treated property as capital asset in books. en-us Fri, 27 Sep 2024 00:00:00 +0530 Mon, 10 Mar 2025 12:57:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766965 ITAT Jaipur upheld CIT(A)'s decision quashing reassessment proceedings initiated after 4 years based on audit objection. The tribunal held that reopening was impermissible as it constituted mere change of opinion on same material facts previously disclosed by assessee during original assessment. Revenue failed to establish non-disclosure of material facts. Additionally, ITAT ruled that change of land use from cinema hall to commercial complex through development agreement did not constitute conversion of capital asset to stock-in-trade under Section 45(2), as assessee was not in real estate business and consistently treated property as capital asset in books. Case-Laws Income Tax Fri, 27 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766965