Notice for reopening U/s. 148 cannot be issued in absence of fresh material

Elecon Engineering Company Ltd. Vs. Asst. CIT (Gujarat High Court) In this case in the queries itself raised during Original Assessment, the assessing officer pointed out that the assessee had purchased immovable property of Rs. 50.72 lacs and sold such property for Rs. 66.34 lacs. It was in response to such a query that the assessee replied pointing out that two different agreements of mutual exchange of land were executed on 17-11-2008. Subsequently, both these agreements were cancelled by a deed dated 12-3-2009 which was also registered. Thus there was no legal or valid transfer of the land...