Assessment notices under s.143(2) and questionnaire upheld; procedural fairness, s.292B estoppel; LTCG taxable in HUF, agri income addition sustained
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....ITAT upholds validity of the assessment proceedings: the notice under s.143(2) and accompanying questionnaire were issued after application of mind and are not mechanical; therefore grounds challenging re-assessment notice and service are dismissed. Procedural fairness is affirmed - multiple opportunities to be heard were afforded and no infirmity found. The contention regarding non-acknowledgement of ITR-V was rejected under the principle in s.292B for participating in proceedings without contemporaneous objection. Non-supply of reasons recorded was not fatal where no formal request was made. Substantive relief granted: long-term capital gains from sale of ancestral land must be assessed in HUF capacity, not in the individual's hands. Addition treating declared agricultural income as undisclosed is upheld.....