Reopening of assessment u/s 147 on the basis of ‘mesne profits’ which is likely to accrue in the future is valid?

 In view of judgment in R.J Wood. The Court held that receipts towards mesne profits should be taxed in the year of their receipt. The revenue had not however, re-opened the assessment in respect of the year of receipt of the amounts, in this case. As a result, this Court holds that though the amount received by the assessee was liable to tax, in accordance with the law declared by the Supreme Court – in the year of its receipt- there is no infirmity with the findings and conclusions of the Tribunal. The questions of law framed are accordingly answered against the revenue, and in favour of ...