Reassessment under s.147 r.w.s.144B quashed for switching from s.50C to s.43CA without recorded reasons on file

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....ITAT allowed the assessee's appeal and quashed the reassessment order passed u/s 147 r.w.s. 144B. The AO had reopened the assessment solely on the belief that income had escaped assessment by non-application of s.50C (capital gains on transfer of land/building). However, in the reassessment, no addition was made under s.50C; instead, the AO invoked s.43CA (business income on transfer of land/building held as stock-in-trade), which was never part of the recorded reasons. Holding this change impermissible, ITAT declared the reassessment invalid and set it aside.....