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    <title>1986 (9) TMI 119 - ITAT DELHI-C</title>
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    <description>Notice to one accountable person was held valid because the estate duty scheme casts a duty on each accountable person to render an account, and the objection was also not raised at the earlier stages. Reopening of the estate duty assessment was held invalid because the statutory reopening provision did not require income-tax style recording of reasons, yet the reopening was based only on material already disclosed in the original statement of account. Since the alleged escapement depended on the same facts already before the authority, the reassessment amounted to a mere change of opinion and was cancelled.</description>
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      <link>https://www.taxtmi.com/caselaws?id=64182</link>
      <description>Notice to one accountable person was held valid because the estate duty scheme casts a duty on each accountable person to render an account, and the objection was also not raised at the earlier stages. Reopening of the estate duty assessment was held invalid because the statutory reopening provision did not require income-tax style recording of reasons, yet the reopening was based only on material already disclosed in the original statement of account. Since the alleged escapement depended on the same facts already before the authority, the reassessment amounted to a mere change of opinion and was cancelled.</description>
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