https://www.taxtmi.com/caselaws?id=778068 ITAT held that the reopening of assessment by the AO under s.148 was invalid as it amounted to impermissible review/change of opinion after a completed s.143(3) scrutiny. The tribunal found the AO's reasons ignored Specific Relief and Transfer of Property Acts and confirmed that relinquishment of the right to seek specific performance in exchange for money extinguished the right in property, attracting s.2(14) read with s.2(47) as a transfer. Earlier assessment allowing LTCG and s.54/54F reliefs was sustained; re-opening notice quashed and appeal allowed. en-us Wed, 15 Jan 2025 00:00:00 +0530 Wed, 10 Sep 2025 08:39:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=778068 ITAT held that the reopening of assessment by the AO under s.148 was invalid as it amounted to impermissible review/change of opinion after a completed s.143(3) scrutiny. The tribunal found the AO's reasons ignored Specific Relief and Transfer of Property Acts and confirmed that relinquishment of the right to seek specific performance in exchange for money extinguished the right in property, attracting s.2(14) read with s.2(47) as a transfer. Earlier assessment allowing LTCG and s.54/54F reliefs was sustained; re-opening notice quashed and appeal allowed. Case-Laws Income Tax Wed, 15 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=778068