Assessment Reopening u/s 148 on Title Improvement Fails to Affect Short-Term Capital Gains Taxability.

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....Reopening of assessment u/s 148 – The conversion from lease hold to a free hold being an improvement of the title, does not have any effect on the taxibility of profits as short term capital gains - the notices issued u/s 148 of the Act does not comply with the proviso to Section 147 and 149 of the Act - HC....