Dismissing the appeal of the revenue the Court held that  reassessment is bad in law and  as the  joint development agreement, power of attorney, the mortgage were all in force at the relevant time. In fact, even on the date when the Assessing Officer completed the assessment under section 147 of the Act by order dated March 25, 2015, the joint development agreement was not rescinded and the power of attorney was not cancelled. Therefore, on the facts, the Assessing Officer could not have held that this was on account of a windfall gain to be brought to tax under the head “Income from other sources”.( AY.2007-08)