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Reassessment Invalid for Change of Opinion on 54F Claim – ITAT Quashes ₹1.63 Cr LTCG Addition
Case Law Details
- Case Name
- Kamaluddin Hamed Salmani Vs DCIT (ITAT Hyderabad)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2016-17
- Courts
- All ITAT, ITAT Hyderabad
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Kamaluddin Hamed Salmani Vs DCIT (ITAT Hyderabad)
Reassessment Void When Issue Already Examined in Original Scrutiny- No Fresh Material- Change of Opinion on 54F Claim Not Permitted- ITAT Quashes ₹1.63 Cr LTCG Addition Under 54F Reopening
Assessee’s reassessment u/s 147 was initiated on the ground that capital gains exemption u/s 54F was wrongly claimed on sale of land, as the new property was allegedly received in loan settlement & not purchased from sale proceeds. The AO treated ₹1.63 crore as taxable LTCG, & the CIT(A) confirmed it.
Assessee contended that the issue of 54F exe...



