Assessee, an NRI, had entered into an MOU on 21-3-2016 with one ‘GNC’ and 11 other persons for clearing of pending litigation in respect of agricultural land situated at Manchirevula Village. Assessee had also entered into 2 agreements of sale cum GPA, both dated 21-3-2016 with ‘GNC’ and others for purchase of 2 parcels of land against consideration which was paid through banking channels. All these documents were presented before the Joint Registrar and were duly registered on 24-3-2016. On the basis of the reporting of said transaction vide agreement of sale cum GPA, Assessing Officer reopened assessment of assessee by issuing notice under section 148 dated 30-3-2021.On appeal, the CIT(A) held that, held that there was no transfer of immovable property by way of these documents, namely agreement of sale cum GPA dated 21-3-2016, because the vendors in these documents did not have valid possession of the said property and, therefore, due to lack of handing over of physical possession of the land, there was no transfer of immovable property. On appeal by the revenue, the  Assessee raised an issue of the validity of reopening by invoking Rule 27 of the ITAT Rules, 1963. Tribunal held that documents were duly signed by parties and presented for registration on 24-3-2016, and thereupon these documents were registered on 24-3-2016. Thus, the transaction of sale of land was completed on the date when these documents were presented before the Sub-Registrar and thereafter, registered on 24-3-2016, which fell in the financial year 2015-16 relevant to assessment year 2016-17 and not in the financial year 2016-17 relevant to assessment year 2017-18.  Therefore, reopening of assessment for year under consideration was not valid. Order of CIT(A) was affirmed. (AY. 2017-18)