AO’s Apprehension Not Evidence – Section 50C Inapplicable to Leasehold; Reassessment on Change of Opinion Invalid

ACIT Vs Mazagon Dock Shipbuilders Ltd. (ITAT Mumbai) AO’s Apprehension Not Evidence & No 50C on Leasehold Rights- Reassessment Based on Audit Note = Change of Opinion, Not Permissible; Revenue Fails in Rs. 318 Lakh Lease Transfer Dispute – ITAT Quashes 147 Action Assessee, a 100% Government of India undertaking under the Ministry of Defence, had originally filed its return declaring income of Rs. 133.58 crore which was assessed u/s 143(3) at Rs. 136.25 crore. Subsequently, AO issued notice u/s 148 on 26.03.2012 alleging that capital gains from transfer of leasehold land to employee ho...