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2012 (2) TMI 234 - ITAT, CHANDIGARHTrust - Transfer versus Donation - Held That:- Transfer of assets for consideration, from one society to another, which has been received by way of book entries and cannot be a donation - Taxable as "Capital Gain". RE-assessment under 147 - reasons to believe - Capital Gain not charged to tax - Held That:- The re-opening of the assessment for bringing the capital gains to tax which was omitted earlier does not amount to change of opinion. The omission to apply the provisions of the Act and later on applying them is a valid ground for invoking notice under 148.
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