Reassessment Invalid for Change of Opinion on 54F Claim – ITAT Quashes ₹1.63 Cr LTCG Addition

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...