https://www.taxtmi.com/caselaws?id=779252 The HC quashed the reopening proceedings under s.147/148, holding that withdrawal of exemption under s.47A and consequent recomputation must proceed under s.155(7B) rather than by treating subsequent events as escapement of income to justify s.147/148. The AO, who accepted the transferee's treatment of the sale as capital asset and the capital gains paid, could not adopt a contrary view against the transferor; inconsistent positions are impermissible. If the transferee had genuinely sold as stock-in-trade, the AO could invoke s.47A and s.155(7B) within the statutory period, but here proceedings were time-barred and thus invalid, so impugned notices were quashed. en-us Tue, 26 Aug 2025 00:00:00 +0530 Tue, 30 Sep 2025 14:42:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779252 The HC quashed the reopening proceedings under s.147/148, holding that withdrawal of exemption under s.47A and consequent recomputation must proceed under s.155(7B) rather than by treating subsequent events as escapement of income to justify s.147/148. The AO, who accepted the transferee's treatment of the sale as capital asset and the capital gains paid, could not adopt a contrary view against the transferor; inconsistent positions are impermissible. If the transferee had genuinely sold as stock-in-trade, the AO could invoke s.47A and s.155(7B) within the statutory period, but here proceedings were time-barred and thus invalid, so impugned notices were quashed. Case-Laws Income Tax Tue, 26 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779252