On Writ filed, the High Court held that land was purchased in the name of Assessee (not as a trustee / agent of a trust as contended by the Assessee) as the sale deed, certificate of Registrar as well as order of District Magistrate clearly indicated the name of Assessee as purchaser and hence reopening was valid. (AY. 2014-2015)
Chandra Mohan Tiwari .v. ITO (2018) 168 DTR 251/(2020) 314 CTR 750 (All.)(HC)
S. 147 : Reassessment – Within four years- No where it has been mentioned that the property has been purchased by the assessee as a trustee/agent of the trust instead evidences prove Assessee himself to be the purchaser – Hence, re-opening is valid. [S. 148]