2018 (4) TMI 341

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.... The Revenue appeals to this Court under Section 260A of the Income Tax Act, 1961 [hereafter "the 1961 Act"], complaining that the deletion of Rs. 69,30,800/- by the lower appellate authorities is contrary to Section 54B of the 1961 Act. The assessment was completed on 19.12.2008; the assessee had reported sale of agricultural land which was acquired for an initial consideration of Rs. 94,88,94....

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....ns 147/148 of the 1961 Act was not justified as it amounted to fresh opinion and, therefore, an impermissible review and that, even on the merits, the addition was not justified. The Tribunal followed suit. It is firstly contended that the Tribunal's finding that the Revenue did not urge any ground with respect to the reopening of the assessment is incorrect because a general ground in support ....