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Reopening of assessment based on purported guideline value of Rs. 16,000/- per sq. ft. for property was erroneous. Records showed guideline value was Rs. 12,000/- per sq. ft. for residential property, not commercial. u/s 47A of Indian Stamps Act, 1899, jurisdictional registering officer is competent authority to determine undervaluation for stamp duty purposes. Property registration at Rs. 12,000/- per sq. ft. indicates no undervaluation. Reopening inspired by mere change of opinion without new tangible material is impermissible as per Supreme Court's decision in Kelvinator of India Ltd. Sections 148 cannot be invoked for reviewing completed assessment based on change of opinion.
Reopening of assessment based on purported guideline value of Rs. 16,000/- per sq. ft. for property was erroneous. Records showed guideline value was Rs. 12,000/- per sq. ft. for residential property, not commercial. u/s 47A of Indian Stamps Act, 1899, jurisdictional registering officer is competent authority to determine undervaluation for stamp duty purposes. Property registration at Rs. 12,000/- per sq. ft. indicates no undervaluation. Reopening inspired by mere change of opinion without new tangible material is impermissible as per Supreme Court's decision in Kelvinator of India Ltd. Sections 148 cannot be invoked for reviewing completed assessment based on change of opinion.
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