Independent valuation inquiry is essential before reopening capital gains assessment solely on a co-owner's valuation report.

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....Reassessment initiated in the name of a deceased assessee is invalid, and the resulting notice and order cannot be sustained where section 159(2)(b) applies. For extended reassessment limitation, capital gains from land may constitute income represented in the form of an asset when the sale proceeds are deposited in a bank account, because bank deposits fall within the inclusive statutory explanation. Reassessment for alleged understatement of capital gains cannot rest solely on a co-owner's valuation report. The Assessing Officer must undertake an appropriate independent valuation inquiry, examine valuation methodology, apply independent mind, and form the required belief of income escaping assessment.....