https://www.taxtmi.com/caselaws?id=56116 The Tribunal upheld the CIT (Appeals) findings, dismissing challenges to the validity of proceedings under section 147(a) for assessment years 1977-78 to 1979-80. It ruled that the income was fully disclosed, and the ITO's decision to reopen assessments was unjustified. Regarding assessability of income from properties under section 22, the Tribunal determined that notional ALV should not be added to the assessee's income as ownership entails dominion over the property. The interpretation of "owner" in section 22 emphasized enjoyment of income, leading to the dismissal of all appeals based on principles of real income taxation. en-us Mon, 01 Feb 1993 00:00:00 +0530 Wed, 01 Dec 2010 16:34:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=56116 The Tribunal upheld the CIT (Appeals) findings, dismissing challenges to the validity of proceedings under section 147(a) for assessment years 1977-78 to 1979-80. It ruled that the income was fully disclosed, and the ITO's decision to reopen assessments was unjustified. Regarding assessability of income from properties under section 22, the Tribunal determined that notional ALV should not be added to the assessee's income as ownership entails dominion over the property. The interpretation of "owner" in section 22 emphasized enjoyment of income, leading to the dismissal of all appeals based on principles of real income taxation. Case-Laws Income Tax Mon, 01 Feb 1993 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=56116