TaxTMI 
TaxTMI 
DVO report u/s 131(i)(d)
08 Jun 2010 
4 Replies 
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Reassessment power: DVO reports can support reopening if statutory conditions are met, but not when they amount to a mere change of opinion.
A DVO report may justify reopening an assessment if the statutory conditions for reassessment are satisfied; it can be a ground for reopening when referenced before completion of original assessment and may permit recomputation in consequence of such reference. If the original assessment was made on full facts and the DVO report is obtained only thereafter, reliance on it may constitute a mere change of opinion and thus not be a lawful basis for reassessment. Valuation differences and wealth tax issues require fact-specific analysis. (AI Summary)
A DVO report may justify reopening an assessment if the statutory conditions for reassessment are satisfied; it can be a ground for reopening when referenced before completion of original assessment and may permit recomputation in consequence of such reference. If the original assessment was made on full facts and the DVO report is obtained only thereafter, reliance on it may constitute a mere change of opinion and thus not be a lawful basis for reassessment. Valuation differences and wealth tax issues require fact-specific analysis. (AI Summary)
can the A.O REOPEN THE ASSESSEMENT BASED ON DVO REPORT