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2005 (8) TMI 35 - HC - Income Tax"(i) Whether the reopening of the assessment under section 148 read with section 147 of the Act after the expiry of four years can be made on the basis of the report of the Valuation Officer who has been appointed under section 131(1)(a) of the Act for proper valuation of the cost of construction of the building? (ii) Whether the report of the Valuation Officer in any event is merely an opinion and can be relied upon as a material or evidence on the basis of which the sum of Rs. 12,32,954 can be treated as the undisclosed income of the assessee when the said amount of Rs. 12,32,954 as undisclosed income of the assessee is without any material or evidence?" - we answer both the questions in the negative
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