https://www.taxtmi.com/caselaws?id=774808 ITAT Chandigarh dismissed revenue's appeal challenging CIT(A)'s deletion of LTCG addition related to escrow amount in slump sale. AO reopened assessment u/s 147 claiming assessee under-declared LTCG by excluding escrow amount in AY 2012-13. ITAT held reopening unjustified as original assessment u/s 143(3) already disclosed all relevant facts including slump sale agreement and escrow details. Reassessment constituted impermissible change of opinion without fresh material. Regarding LTCG addition, ITAT agreed escrow amount was contingent, not guaranteed in AY 2012-13, depending on condition fulfillment. Assessee lacked absolute right to receive amount during relevant year, becoming receivable only subsequently. en-us Mon, 09 Jun 2025 00:00:00 +0530 Tue, 15 Jul 2025 08:39:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774808 ITAT Chandigarh dismissed revenue's appeal challenging CIT(A)'s deletion of LTCG addition related to escrow amount in slump sale. AO reopened assessment u/s 147 claiming assessee under-declared LTCG by excluding escrow amount in AY 2012-13. ITAT held reopening unjustified as original assessment u/s 143(3) already disclosed all relevant facts including slump sale agreement and escrow details. Reassessment constituted impermissible change of opinion without fresh material. Regarding LTCG addition, ITAT agreed escrow amount was contingent, not guaranteed in AY 2012-13, depending on condition fulfillment. Assessee lacked absolute right to receive amount during relevant year, becoming receivable only subsequently. Case-Laws Income Tax Mon, 09 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774808