Finalized Assessment Cannot Be Reopened for Property Deed Re-registration
In a recent case involving Dabur India Ltd vs ACIT (ITAT Delhi), the assessments for the year 2011-12 came under scrutiny due to a reassessment initiated by the Assessing Officer (AO). The key issue at hand was the validity of the reassessment and adjustments made to capital gains related to the sale of immovable property.
Background of Dabur India Ltd
Dabur India Ltd, a renowned manufacturer and trader of herbal and FMCG products, initially reported an income of Rs. 253,24,04,903 for the year. Following certain adjustments, the AO completed a regular assessment under section 143(3), setting the total income at Rs. 296,28,03,260.
Reassessment Controversy
The AO later reopened the assessment for the same year based on information regarding the sale of immovable property and discrepancies in the valuation. Dabur India Ltd challenged this action, stating that the reassessment was time-barred as it exceeded the four-year limit from the original assessment.
Grounds of Appeal
Dabur India Ltd raised several objections in their appeal, including the application of sections 50C and 43CA to enhance the sale consideration of immovable assets, timing issues related to capital gains calculation, incorrect computation of book profit under section 115JB, disallowance of setting off long-term capital gains with previous losses, and the imposition of interest under sections 234A and 234B.
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Introduction
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Main Body
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Conclusion
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References
1. Lorem Ipsum, et al. (2020) “Lorem Ipsum: A Study in Contrasts.” Journal of Lorem 15(3): 123-145.
2. Ipsum, L. et al. (2019) “Contrasts in Lorem Ipsum Usage.” Lorem Journal 10(2): 67-89.
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