Limited scrutiny with the verification of specific issue of Computation of Capital Gain and the deductions claimed thereon u/s 54F. Requisite details about the transaction of sale and purchase of immovable property and working of Capital gain with all necessary evidences furnished at the time of filing the original return and also in the scrutiny assessment. Assessment framed u/s 143(3) accepting the income declared in the return of income filed. The objection of the assessee for objecting the reassessment is rejected. On writ allowing the petition the Court held that, reassessment is mere change of opinion hence the notice and order disposing the objection is quashed. Relied on CIT v. Kelvinator of India Ltd. [2010] 187 Taxman 312/320 ITR 561 (SC) (para 11) followed. (AY. 2016-17)
Hareshkumar Bhupatbhai Panchani v. ITO (2024) 301 Taxman 363 (Guj)(HC)
S. 147 : Reassessment-Long term capital gain-Limited scrutiny-Change of opinion-Reassessment notice and order disposing the objection is quashed. [S.54F,143(3), 148, Art. 226]