ORDER

Per Jason P Boaz:

These four appeals by the assessee are directed against the separate orders of CIT(A)-Davangere, all dated 06.08.2018, for Assessment Years 2010-11 to 2013-14. Since the issues involved in all these appeals are identical and the background facts common, we deem it appropriate to dispose off these appeals by way of this common order for the sake of convenience.

2. Briefly stated, the facts of the case are as under:

2.1 For Assessment Year 2010-11, the assessee filed her return of income on 31.07.2010 declaring total income of Rs.2,23,590/- and agricultural income of Rs.2,07,000/-. The income declared included capital gains in respect of sale of sites formed on land measuring 2 acres and 12 guntas at Mathod Village, Shivamogga. The aforesaid land purchased on 17.02.19973 was agricultural land, which was subsequently converted for non-agricultural purposes, thereafter plotted into residential sites and the assessee declared ‘Long Term Capital Gains’ (LTCG) on sale of these sites. The case was taken up for scrutiny and the assessment was completed under section 143(3) of the Income Tax Act, 1961 (in short ‘the Act’) vide order dated 31.03.2012, accepting the returned income. Subsequently, the Assessing Officer (AO) initiated proceedings under section 147 of the Act on the ground that income of the assessee exigible to tax had escaped assessment since the income declared by the assessee under the head “LTCG” was incorrect and the same had to be assessed under the head “Business Income”. On receipt of the reasons recorded by the AO, the assessee filed objections on the re-opening of the assessment and also put forth submissions on merits. The AO, however, rejected the claims put forth by the assessee and completed the re-assessment under section 143(3) r.w.s. 147 of the Act, vide order dated 10.03.2016; wherein the income on sale of sites declared by the assessee as LTCG was assessed under the head ‘Business’. In view of this, the assessee’s claims for setting off of brought forward loss of Rs.1,19,407/- and exemption under section 54F of the Act of Rs.13,21,540/- was disallowed by the AO.

2.2 For Assessment Year 2011-12, the assessee field her return of income on 29.07.2011 declaring total income of Rs.1,03,710/- and agricultural income of Rs.1,03,710/-. The case was taken up for scrutiny and the assessment completed under section 143(3) of the Act vide order dated 17.02.2013; wherein, inter alia, an addition of Rs.17,37,800/- was made under ‘Short Term Capital Gains’ (STCG) on account of sale of agricultural land as against Rs.1,35,000/- declared by the assessee; and the assessee’s income was assessed at Rs.17,11,707/- after allowing deduction of Rs.1 lakh under section 80C of the Act. Thereafter, the AO initiated proceedings under section 147 of the Act, after noticing that the assessee’s income liable to tax had escaped assessment as the assessee had not declared income on sale of sites, on the aforesaid land at Mathod Village, Shivamogga, during the year under consideration and issued notice under section 148 of the Act dated 31.12.2015 to the assessee. In response thereto, the assessee filed a return of income on 12.08.2016, offering income from “Capital Gains” on sale of sites at Mathod Village, Shivamogga. In the course of assessment, the assessee had filed objections to the re-opening of assessment for this year, as well as the proposed treatment of income from sale of sites as “Business Income”. The AO rejected the assessee’s claims and completed the re-assessment under section 143(3) r.w.s. 147 of the Act vide order dated 27.12.2016; wherein the income on sale of sites declared by the assessee as ‘LTCG’ was assessed by the AO under the head “Business Income”, by taking the same view as in the earlier Assessment Year 2010-11.

2.3 For Assessment Year 2012-13, the assessee, as in the earlier Assessment Year, had not declared income from sale of sites at Mathod Village, Shivamogga in the return of income fil