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.

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