Assessment Reopened u/s 147 Based Solely on DVO Report Lacks Additional Evidence of Income Escaping Assessment.

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....Reopening of assessment u/s 147 - difference pointed out by the DVO in his valuation report - There should be a live link between the material coming to the notice of the Assessing Officer and the formation of belief regarding the escapement of income. In the present case, there is no material except the valuation report of DVO which has a live link and base for the assessing officer to form a belief regarding the escapement of income. Rather, the natural conclusion which can be drawn is that the assessing officer has re-opened the assessment on the basis of DVO's valuation report - AT....