Allowing the petition the Court held that the revenue failed to show which necessary facts were not disclosed by assessee at stage of previous assessment proceedings Since no new material surfaced during reassessment proceedings the notice was held to be bad in law. (AY. 2002-03)
Kavitaben Jaysukhbhai Zalawadiya v. ITO (2021) 282 Taxman 265 (Guj.)(HC)
S. 147 : Reassessment-After the expiry of four years-Capital gains-Land used for agricultural purposes-No new material-Reassessment notice was quashed. [S. 54B, 148, Art. 226]