Writ relief against show cause notices is available where jurisdiction is absent and concluded advance rulings cannot be reopened without fresh fraud ...
HC quashed orders rejecting assessee's request for revision u/s 264. Differential value between sale deed and stamp duty valuation exceeded Rs. 50,000, invoking Section 56(2)(vii)(b)(ii). Stamp duty valuation of Rs. 97,69,000 adopted by SRO to be considered for computing income. AO to refer valuation to Valuation Officer if disputed u/s 50C(2). Assessee can raise objections before revisional authority u/s 264 or appellate authority u/s 246A. Cases remitted to AO for fresh adjudication u/s 56(2)(vii)(c) proviso read with Section 50C(2).
HC quashed orders rejecting assessee's request for revision u/s 264. Differential value between sale deed and stamp duty valuation exceeded Rs. 50,000, invoking Section 56(2)(vii)(b)(ii). Stamp duty valuation of Rs. 97,69,000 adopted by SRO to be considered for computing income. AO to refer valuation to Valuation Officer if disputed u/s 50C(2). Assessee can raise objections before revisional authority u/s 264 or appellate authority u/s 246A. Cases remitted to AO for fresh adjudication u/s 56(2)(vii)(c) proviso read with Section 50C(2).
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