Mere Entering into Development Agreement doesn’t Allow Section 45(2) Invocation: ITAT Jaipur

DCIT Vs Man Prakash Talkies Pvt Ltd. (ITAT Jaipur) ITAT Jaipur held that mere entering into the Development Agreement would not permit invocation of section 45(2) of the Income Tax Act. There is no positive act which indicates that the assessee has treated capital asset as stock-in-trade. Facts- Revenue has preferred the present appeal mainly on the ground that whether CIT(A) is right in quashing the reopening proceedings of AO ignoring the fact that the assessee has converted its capital reopening proceedings of AO ignoring the fact that the assessee has converted its capital asset into stock...