Dispute over capital gains assessment for property sale; individual challenges fair market value u/ss 147/144, 160-162.

Reopening of assessment - capital gain on sale of property - assessee was appointed as the power of attorney holder by the owner in respect of her immovable property - sale in “Individual capacity” as against “representative assessee of owner" - the order so passed by the AO in the impugned set-aside proceedings u/s 147/144/set-aside has been passed in the capacity of the assessee as representative assessee of owner and continues to carry the same consequences and implication in terms of section 160, 161 and 162 of the Act as the original order passed u/s 147/144 except for the variation of the fair market value which the assessee has challenged and we shall be dealing while adjudicating the subsequent ground of appeal. - AT .....

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