Reopening Upheld but Addition Restored – Non-Speaking Order on Cost of Improvement

Kuldip Kumar Goel Vs ACIT (ITAT Delhi) The ITAT Delhi partly allowed the assessee’s appeal in a reassessment case relating to sale of immovable property where the AO had disallowed 50% of the claimed cost of improvement (₹44.05 lakh) while computing capital gains. The Tribunal upheld the validity of reopening u/s 147, noting that fresh tangible material such as AIR data regarding property sale and non-response to notices justified formation of “reason to believe” and reopening was not a mere change of opinion. Jurisdictional and procedural objections were also rejected. However, on mer...