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    <title>2021 (6) TMI 540 - ITAT JAIPUR</title>
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    <description>Reopening under section 147 read with section 148 could not be sustained because no pre-existing material was shown to the Assessing Officer before recording reasons and issuing notice; later material obtained during reassessment could not cure the defect, so the reassessment initiation failed. The enhanced stamp valuation also could not be adopted under section 50C because no revaluation order or supporting stamp authority record was produced, and the available clarification stated that no reference had been received and no order passed. On both issues, the additions were deleted and the assessee obtained full relief.</description>
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      <description>Reopening under section 147 read with section 148 could not be sustained because no pre-existing material was shown to the Assessing Officer before recording reasons and issuing notice; later material obtained during reassessment could not cure the defect, so the reassessment initiation failed. The enhanced stamp valuation also could not be adopted under section 50C because no revaluation order or supporting stamp authority record was produced, and the available clarification stated that no reference had been received and no order passed. On both issues, the additions were deleted and the assessee obtained full relief.</description>
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