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Revision u/s 263 based on DVO's report received after assessment culmination was invalid as per section 142A(4), DVO failed to provide opportunity of being heard to assessee. Section 142A(6) mandates DVO to send report within six months, which was violated. Report barred by limitation is non-est, cannot be basis for revision u/s 263. Principle of mandatory compliance of 'shall' upheld in B.K. Khanna case. Reliance Jute case held failure to follow prerequisite conditions renders valuation incompetent. Non-disposal of objections to DVO's report by PCIT in revision violates natural justice. DVO's report beyond statutory time limit u/s 142A(6) is against law's mandate, hence revision u/s 263 based on such report unjustified. Assessee's appeal allowed.
Revision u/s 263 based on DVO's report received after assessment culmination was invalid as per section 142A(4), DVO failed to provide opportunity of being heard to assessee. Section 142A(6) mandates DVO to send report within six months, which was violated. Report barred by limitation is non-est, cannot be basis for revision u/s 263. Principle of mandatory compliance of 'shall' upheld in B.K. Khanna case. Reliance Jute case held failure to follow prerequisite conditions renders valuation incompetent. Non-disposal of objections to DVO's report by PCIT in revision violates natural justice. DVO's report beyond statutory time limit u/s 142A(6) is against law's mandate, hence revision u/s 263 based on such report unjustified. Assessee's appeal allowed.
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