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Revision under section 263 was challenged on grounds that the assessing officer erred by accepting a registered valuer's report without referral to the Departmental Valuation Officer; the Tribunal found the AO had applied his mind, examined and verified valuation and adopted a tenable view, so the Pr. CIT's contrary opinion amounted to a post-view. Applying the twin-condition test, the Tribunal held lack of referral or disagreement with the valuer did not establish the assessment was erroneous in law, and therefore the requirements for revision were not satisfied; Pr. CIT's revision order was set aside and the assessment upheld.
Revision under section 263 was challenged on grounds that the assessing officer erred by accepting a registered valuer's report without referral to the Departmental Valuation Officer; the Tribunal found the AO had applied his mind, examined and verified valuation and adopted a tenable view, so the Pr. CIT's contrary opinion amounted to a post-view. Applying the twin-condition test, the Tribunal held lack of referral or disagreement with the valuer did not establish the assessment was erroneous in law, and therefore the requirements for revision were not satisfied; Pr. CIT's revision order was set aside and the assessment upheld.
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