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    <title>1999 (7) TMI 56 - CALCUTTA High Court</title>
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    <description>Reopening of estate duty assessment under section 59(b) requires fresh information coming to the assessing authority after the original assessment; it cannot rest on a mere change of opinion about facts already disclosed. Because the land value had already been disclosed in the estate duty proceedings and the higher figure in wealth-tax proceedings flowed from a different valuation rule, no external new information was available, so the reassessment was unjustified and its cancellation was sustained. By contrast, the Tribunal&#039;s presumption that the original order fell under section 59(a) was supported by material and was not arbitrary, leaving the accountable person&#039;s position intact.</description>
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      <title>1999 (7) TMI 56 - CALCUTTA High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=15879</link>
      <description>Reopening of estate duty assessment under section 59(b) requires fresh information coming to the assessing authority after the original assessment; it cannot rest on a mere change of opinion about facts already disclosed. Because the land value had already been disclosed in the estate duty proceedings and the higher figure in wealth-tax proceedings flowed from a different valuation rule, no external new information was available, so the reassessment was unjustified and its cancellation was sustained. By contrast, the Tribunal&#039;s presumption that the original order fell under section 59(a) was supported by material and was not arbitrary, leaving the accountable person&#039;s position intact.</description>
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      <pubDate>Tue, 20 Jul 1999 00:00:00 +0530</pubDate>
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