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2006 (9) TMI 130 - HC - Income TaxReopening of assessment - Construction of a cinema house and valuation thereof –assessee submitted that the Assessment Officer could not reopen the assessment on the basis of the report of the Valuation Officer for initiation of proceedings under section 147. The opinion of the Departmental Valuer cannot be treated as a reason conclusive to form the belief as contemplated in section 147 - report of the Valuation Officer is an opinion and it may create suspicion and doubt. Suspicion and doubt, in the opinion of this court, cannot be treated as opinion capable of forming reason to believe within the meaning of section 147. Since there is nothing on record to show that the provision of sub-section (2) of section 148 has been complied with, the taxing authorities were not eligible to reopen the assessment under section 147.
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