Devendrasinh Chhatrasinh Vaghela v JT.CIT ( 2018) 97 taxmann.com 173 (Guj)( HC) Editorial: SLP of revenue is dismissed due to low tax effect , JT.CIT (OSD) v. Devendrasinh Chhatrasinh Vaghela. (2019) 266 Taxman 90 (SC)

S.147: Reassessment-After the expiry of four years- Capital gains- No failure on the part of assessee to disclose truly and fairly material facts – Reassessment is held to be bad in law . [ S.50C 54B , 148 ]

Assessee claimed deduction under S. 54B in relation to proceeds received upon sale of agricultural lands .During original assessment proceedings the AO examined claim of assessee at considerable length and had raised multiple queries which were duly replied by assessee . Further, in respect of valuation, AO has proposed to apply S.50C of the Act . Assessee produced sale deeds and pointed out that it was valuation adopted for purpose of stamp duty which was declared as sale proceeds for purpose of income-tax . There was nothing on record to suggest that there was any failure on part of assessee to disclose truly and fully all material facts necessary for assessment . (AY. 2012-13 )