“Section 227(2)”

Non-consideration of a decision by a jurisdictional High Court or the Supreme Court constitutes a mistake apparent from the record. However, non-consideration of a non-jurisdictional High Court decision does not typically amount to such a mistake.

Where the sale consideration for a slump sale is a lumpsum amount, and there is no evidence to indicate the price attributable to specific assets like plant, machinery, or buildings, the excess of the sale consideration over the written-down value of depreciable assets is not automatically taxable as deemed business profit under Section 41(2) merely because depreciation has been allowed.

Expenditure incurred by an assessee to discharge a mortgage created by a previous owner is an allowable deduction in computing capital gains, as it represents the cost of acquisition or perfecting an imperfect title. The assessee's payment to clear the encumbrance is not deductible for capital gains computation.

Where a successor discharges a mortgage created by a previous owner, the amount paid to clear the mortgage debt is considered the cost of acquiring the mortgagee's interest in the property, deductible as the cost of acquisition under section 48 of the Income-tax Act.

No income-tax addition can be made solely based on a valuation report; fair market value cannot replace the actual consideration received.

When an assessee establishes the identity, creditworthiness, and genuineness of a transaction, the burden shifts to the Assessing Officer to disprove it. The Assessing Officer must conduct an inquiry or present contrary evidence to dislodge the assessee's claim.

Information alone does not constitute "reason to believe" for reopening an assessment unless it is investigated and leads to independent reasons recorded by the Assessing Officer. The Assessing Officer must apply their mind to the material before issuing a reassessment notice.

An assessee's own case decided by the Tribunal in their favour, affirmed by the High Court, and with an SLP dismissed by the Supreme Court, establishes precedent for similar claims. Exemption under sections 11/12 cannot be denied if the High Court has ruled against the assessing officer.