2013 (11) TMI 1373

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....essment proceedings relating to Assessment Year 2005-06 were concluded under Section 153A of the Income Tax Act, 1961 on 31st December, 2008 at income of Rs.8,57,235/-. Subsequently, on receipt of District Valuation Officer's (DVO) report, re-assessment proceedings under Section 147/148 of the Act for the period 1st April, 2004 to 31st March, 2005 were initiated. As per the DVO's report, the value....

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....n of the DVO per se is not an information for the purposes of reopening assessment under Section 147 of the Income Tax Act, 1961. The Assessing Officer has to apply his mind to the information, if any, collected and must form a belief thereon. In the circumstances, there is no merit in the civil appeal. The Department was not entitled to reopen the assessment." 3. Learned counsel for the appell....