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2012 (3) TMI 60 - AT - Income TaxValidty of Re-opening under 147 - Assessment under 143 on 28.02.06: Necessary facts and report of Registered valuer on record - Matter referred to DVO under 55A, report received on 13.03.06 - Held That:- Assessee had disclose fully and truly all material facts necessary for his assessment. AO have not formed any ‘reason to believe’ for escapement of LTCG rather he wanted to review the assessment on the basis of opinion of DVO who has opined for a lower fair market value as on 01.04.1981. Assessment under 147 after expiry of 4 years from relevant A/Y is not valid.
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