https://www.taxtmi.com/caselaws?id=789946 Receipts under a memorandum of understanding were treated as taxable income from other sources because the assessee could not show ownership or any subsisting enforceable right in the land, and the property had already been sold earlier. On that factual basis, the sums were not accepted as advance sale consideration. Reopening under Section 147 was also upheld because the Assessing Officer's reasons referred to the relevant transaction and receipt of money, and the incorrect quantum mentioned did not destroy the foundational belief that income had escaped assessment. The additions were sustained and the challenge to reassessment jurisdiction failed. en-us Tue, 13 Jan 2026 00:00:00 +0530 Fri, 17 Apr 2026 08:21:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789946 Receipts under a memorandum of understanding were treated as taxable income from other sources because the assessee could not show ownership or any subsisting enforceable right in the land, and the property had already been sold earlier. On that factual basis, the sums were not accepted as advance sale consideration. Reopening under Section 147 was also upheld because the Assessing Officer's reasons referred to the relevant transaction and receipt of money, and the incorrect quantum mentioned did not destroy the foundational belief that income had escaped assessment. The additions were sustained and the challenge to reassessment jurisdiction failed. Case-Laws Income Tax Tue, 13 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789946