Reference to DVO Incorrect as FMV Exceeds Declared Value for LTCG; AO's Belief in Underreporting Required.

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....LTCG - valuation - reference could be made to DVO only if the value declared by the assessee is in the opinion of AO less than its fair market value - in this case FMV as on 1.4.1981 is more - Reference to DVO is not correct - AT....