Prospective valuation amendment limits reassessment: unamended fair market value reference could not justify reopening based on a registered valuer's ...
Non-disposal of an assessee's objections to reassessment reopening before completion of the assessment vitiates the reassessment, because disposal by a separate speaking order is a mandatory requirement and not a mere procedural formality. Applying its earlier decision in ITO v. Hardeep Singh, the ITAT held that the Assessing Officer had not decided the objections before finalising the reassessment. The annulment of the reassessment was therefore upheld, and the Revenue's reliance on Home Finders Housing Ltd. was not accepted.
Non-disposal of an assessee's objections to reassessment reopening before completion of the assessment vitiates the reassessment, because disposal by a separate speaking order is a mandatory requirement and not a mere procedural formality. Applying its earlier decision in ITO v. Hardeep Singh, the ITAT held that the Assessing Officer had not decided the objections before finalising the reassessment. The annulment of the reassessment was therefore upheld, and the Revenue's reliance on Home Finders Housing Ltd. was not accepted.
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