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Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
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AI Drafter ✕ Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
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Issues: Whether the notice issued for reopening estate duty assessment under section 59 was valid when no supporting material was disclosed and the action was sought to be justified on change of opinion or audit objection.
Analysis: The impugned notice was unsustainable because the record disclosed no information or material forming the basis of the belief required for reopening. A mere change of opinion cannot justify reassessment, and an audit objection cannot by itself supply the jurisdictional basis for action. The principle that an audit note may communicate information but cannot substitute the assessing authority's own independent belief applied equally to the estate duty reopening provision.
Conclusion: The notice was invalid and was rightly quashed in favour of the petitioner.
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