https://www.taxtmi.com/caselaws?id=777122 Reassessment initiated beyond four years was invalid because the recorded reason for reopening depended on treating an unregistered joint development agreement as a transfer under section 2(47)(v) of the Income-tax Act, 1961. An unregistered agreement is not enforceable for section 53A of the Transfer of Property Act, 1882 and therefore cannot support a transfer for capital gains purposes. As the legal basis for forming the belief of escapement failed, the additional jurisdictional condition for reopening after four years was not met. The reassessment notice was therefore bad in law and the reopening was not permitted. en-us Wed, 08 Jan 2025 00:00:00 +0530 Mon, 25 Aug 2025 08:40:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=777122 Reassessment initiated beyond four years was invalid because the recorded reason for reopening depended on treating an unregistered joint development agreement as a transfer under section 2(47)(v) of the Income-tax Act, 1961. An unregistered agreement is not enforceable for section 53A of the Transfer of Property Act, 1882 and therefore cannot support a transfer for capital gains purposes. As the legal basis for forming the belief of escapement failed, the additional jurisdictional condition for reopening after four years was not met. The reassessment notice was therefore bad in law and the reopening was not permitted. Case-Laws Income Tax Wed, 08 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=777122