https://www.taxtmi.com/caselaws?id=779719 ITAT held the reopening beyond four years unsustainable under s.147 proviso because the AO did not allege nondisclosure of relevant particulars, and therefore quashed the reassessment notice. The tribunal also rejected Revenue's apportionment at the year of transfer, affirming that cost of acquisition/improvement already determined earlier could not be revisited. Finally, ITAT reversed the CIT(A)'s enhancement under s.251 that reclassified long-term capital gains as short-term, ruling that an appellate authority may not introduce a new head of income while exercising enhancement jurisdiction. en-us Wed, 22 Jan 2025 00:00:00 +0530 Sat, 11 Oct 2025 09:01:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779719 ITAT held the reopening beyond four years unsustainable under s.147 proviso because the AO did not allege nondisclosure of relevant particulars, and therefore quashed the reassessment notice. The tribunal also rejected Revenue's apportionment at the year of transfer, affirming that cost of acquisition/improvement already determined earlier could not be revisited. Finally, ITAT reversed the CIT(A)'s enhancement under s.251 that reclassified long-term capital gains as short-term, ruling that an appellate authority may not introduce a new head of income while exercising enhancement jurisdiction. Case-Laws Income Tax Wed, 22 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779719