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    <title>2024 (7) TMI 440 - GUJARAT HIGH COURT</title>
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    <description>The Gujarat HC quashed reassessment notices under Section 148 for capital gains on co-owned land sale. The court held that reassessment proceedings based on DVO valuation report from co-owner&#039;s case were invalid as reasons recorded failed to mention forming &quot;reason to believe&quot; due to DVO report. Since petitioner fully disclosed material facts during original assessment, reopening constituted mere change of opinion. The court applied principle that co-owners are entitled to same treatment, noting that when reassessment notice was held invalid for co-owner on same grounds, similar notice for petitioner could not be sustained. Petition allowed.</description>
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    <pubDate>Fri, 14 Jun 2024 00:00:00 +0530</pubDate>
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      <title>2024 (7) TMI 440 - GUJARAT HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=755220</link>
      <description>The Gujarat HC quashed reassessment notices under Section 148 for capital gains on co-owned land sale. The court held that reassessment proceedings based on DVO valuation report from co-owner&#039;s case were invalid as reasons recorded failed to mention forming &quot;reason to believe&quot; due to DVO report. Since petitioner fully disclosed material facts during original assessment, reopening constituted mere change of opinion. The court applied principle that co-owners are entitled to same treatment, noting that when reassessment notice was held invalid for co-owner on same grounds, similar notice for petitioner could not be sustained. Petition allowed.</description>
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      <pubDate>Fri, 14 Jun 2024 00:00:00 +0530</pubDate>
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