None
RU
AO’s Apprehension Not Evidence – Section 50C Inapplicable to Leasehold; Reassessment on Change of Opinion Invalid
[]
taxguruin
Since no details of transfer have been furnished during the assessment proceedings u/s.
Further, no details of the transfer had been furnished during the assessment proceedings u/s.
Further, on merits of the case, assessee strongly contended that provisions of section 50C do not apply to the facts of the assessee.
However, a bare perusal of reasons recorded for reassessment and the original assessment proceedings under Section 143(3) makes it clear that the point on which the re- assessment proceedings were initiated, was well considered in the original proceedings being part of audit report.
Assessing Officer in the original assessment proceedings and nothing new in this context has been brought on record to initiate the reopening proceedings.
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