Reopening Valid Where AO Formed No Opinion, AOP Member's 35% Gross-Receipt Share Taxable: Supreme Court in Sanand Properties v. Jt. CIT [2026 INSC 472]
Supreme Court upholds reopening of Sanand Properties' assessments for AY 2007-08 and 2008-09, holding that the AO never formed an opinion on the nature of its AOP income. Its 35% share of the AOP's gross sale receipts, bearing no expenses, is a business receipt taxable in its own hands.
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