https://www.taxtmi.com/caselaws?id=56052 Reassessment of gift-tax valuation was held invalid where it was founded on a revenue audit objection and a different method of valuing unquoted shares. The prevailing Board circular for the relevant year governed the original assessment, and a later revision could not be applied retrospectively to withdraw that benefit. The audit note expressed only a view on the legal position and did not amount to "information" for reopening under section 16(1)(b). Reopening based on a new valuation approach that would merely increase tax was treated as a change of opinion. Goodwill arising after the relevant valuation date also could not be included to enhance share value, so the reassessment was annulled. en-us Tue, 03 Apr 1984 00:00:00 +0530 Wed, 25 Jan 2012 16:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=56052 Reassessment of gift-tax valuation was held invalid where it was founded on a revenue audit objection and a different method of valuing unquoted shares. The prevailing Board circular for the relevant year governed the original assessment, and a later revision could not be applied retrospectively to withdraw that benefit. The audit note expressed only a view on the legal position and did not amount to "information" for reopening under section 16(1)(b). Reopening based on a new valuation approach that would merely increase tax was treated as a change of opinion. Goodwill arising after the relevant valuation date also could not be included to enhance share value, so the reassessment was annulled. Case-Laws Income Tax Tue, 03 Apr 1984 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=56052