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of <h1>Tax Reassessment Blocked: Independent Evaluation Required for Reopening Assessment Under Section 147 Confirmed by Supreme Ruling</h1> <h3>Assistant Commissioner of Income-tax Versus. Dhariya Construction Co.</h3> SC held that a District Valuation Officer's opinion alone is insufficient to reopen a tax assessment under section 147. The Assessing Officer must ... Reopening of the assessment - based on the opinion given by the District Valuation Officer - opinion of the DVO per se is not an information for the purposes of reopening assessment under section 147 of the Income-tax Act,1961 – Held that: - Department was not entitled to reopen the assessment. The Supreme Court of India held that the opinion of the District Valuation Officer (DVO) alone does not constitute 'information' sufficient to reopen an assessment under section 147 of the Income-tax Act, 1961. The Assessing Officer must independently apply mind to any information collected and form a belief to justify reopening. Consequently, the Department was not entitled to reopen the assessment. The civil appeal was dismissed with no order as to costs.
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