The transfer that has taken place according to the 2nd JDA cannot give rise to the reopening of the case concerning the 1st JDA.
The Hyderabad bench of the Income Tax Appellate Tribunal (ITAT) held that reopening of the assessment under Section 147 of the Income Tax Act, 1961 cannot be initiated when no transfer took place on account of the Joint Development Agreement (JDA) entered by a group of assessee. The assessee being an NRI has filed the…
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