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2018 (6) TMI 35 - HC - Income TaxReopening of the assessment u/s 147 - change of opinion - unexplained investment - Held that:- Assessment was completed under Section 143(3) based upon the valuation report of an approved valuer - inspection have been conducted after 7 years of assessmen by the Departmental valuer and difference in value of unexplained investments was found - since the report given by the Departmental valuer is only an estimate and based on such estimation, there cannot be any reopening and if the same is permitted, it would amount to a clear case of change of opinion - case is dismissed - Decided in favor of assessee.
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