Description:
Reassessment- Change of opinion-Assessment under s.143(3) vis-à-vis absence of new material deed of land evidencing the value adopted by the stamp valuation authority at a higher figure than the actual sale consideration received by him, and the assessment having been completed unders.143(3). Reassessment proceedings initiated by the AO for applying the provisions of s.50C was based on changes of opinion already entertained in the regular assessment and, therefore, same is not valid.
– Manmal Jain vs.:ITO (Jd) 27 DTR 103 (2009).
Source:
1. www.icaihyd.org
2. HYDERABAD BRANCH OF SIRC NEWSLETTER.Volume:12 Issue:8. August,2010,Page No.12
Our comment:
The Reassessment proceedings cannot be initiated for change of opinion on land valuation once adopted by Assessing officer during Assessment proceedings