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    <title>2000 (6) TMI 116 -   ITAT AGRA</title>
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    <description>Audit information was treated as factual material, not a mere opinion on law, so reopening under section 59 of the Estate Duty Act, 1953 was held valid and the change-of-opinion challenge failed. Two separately numbered but contiguous units were also held to form one residential house where they lay within one compound, shared common boundaries, and had been converted into a single dwelling; separate municipal numbers were not decisive. On that basis, exemption under section 33(1)(n) was allowed for both units as one house, giving the accountable person partial relief.</description>
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      <title>2000 (6) TMI 116 -   ITAT AGRA</title>
      <link>https://www.taxtmi.com/caselaws?id=54993</link>
      <description>Audit information was treated as factual material, not a mere opinion on law, so reopening under section 59 of the Estate Duty Act, 1953 was held valid and the change-of-opinion challenge failed. Two separately numbered but contiguous units were also held to form one residential house where they lay within one compound, shared common boundaries, and had been converted into a single dwelling; separate municipal numbers were not decisive. On that basis, exemption under section 33(1)(n) was allowed for both units as one house, giving the accountable person partial relief.</description>
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