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    <title>1980 (3) TMI 173 - ITAT MADRAS-B</title>
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    <description>Reassessment under the Gift-tax Act could not be sustained on the basis of a later Board circular and a reappraisal of the same material, because the original assessment had been completed under the then prevailing guidance and no new material was shown; the reopening was therefore without jurisdiction. On valuation, the statutory test remained fair market value, and the original break-up method, supported by recognised administrative guidance and comparable share transactions, was not shown to be contrary to that test. The substituted higher valuation was accordingly rejected, and the cancellation of reassessment was sustained in favour of the assessee.</description>
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      <title>1980 (3) TMI 173 - ITAT MADRAS-B</title>
      <link>https://www.taxtmi.com/caselaws?id=69760</link>
      <description>Reassessment under the Gift-tax Act could not be sustained on the basis of a later Board circular and a reappraisal of the same material, because the original assessment had been completed under the then prevailing guidance and no new material was shown; the reopening was therefore without jurisdiction. On valuation, the statutory test remained fair market value, and the original break-up method, supported by recognised administrative guidance and comparable share transactions, was not shown to be contrary to that test. The substituted higher valuation was accordingly rejected, and the cancellation of reassessment was sustained in favour of the assessee.</description>
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