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    <title>1984 (6) TMI 101 - ITAT CHANDIGARH</title>
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    <description>Rectification under section 61 of the Estate Duty Act could not be used to alter share valuation where the same issue had already been taken up in reassessment proceedings that were later annulled. The ITAT held that no mistake apparent from the record was shown; the later attempt rested only on a different valuation view, amounting to a change of opinion. Section 61 could not operate as a substitute for reassessment or as a back-door method to revive a concluded valuation dispute, so the revised valuation order could not stand and the assessee succeeded.</description>
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      <title>1984 (6) TMI 101 - ITAT CHANDIGARH</title>
      <link>https://www.taxtmi.com/caselaws?id=61304</link>
      <description>Rectification under section 61 of the Estate Duty Act could not be used to alter share valuation where the same issue had already been taken up in reassessment proceedings that were later annulled. The ITAT held that no mistake apparent from the record was shown; the later attempt rested only on a different valuation view, amounting to a change of opinion. Section 61 could not operate as a substitute for reassessment or as a back-door method to revive a concluded valuation dispute, so the revised valuation order could not stand and the assessee succeeded.</description>
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      <pubDate>Sat, 30 Jun 1984 00:00:00 +0530</pubDate>
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