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2009 (10) TMI 16 - ALLABAHAD HIGH COURTValidity of notice issued u/s 147 – held that - The case on hand is indisputably not a case for computation of capital gains. The dispute relates with regard to the investment in the building made by the petitioner-company during the relevant assessment years. - no reference to the Valuation Cell could have been made for the purposes of determining the investment made by the petitioner in the building - report of D.V.O cannot form relevant material for the purposes of assessment of Income Tax of a assessee. If it cannot form basis for the purposes of determining the investment made by the assessee for the building, obviously it is not a relevant material so far as re-assessment proceedings are concerned – notice u/s 147 scrapped.
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