S. 147 : Reassessment-Revaluation of asset of firm-Transfer of revalued reserve to partners’ accounts-Section 45(3) is applicable in year of transfer of capital asset by partner to firm by way of capital contribution-Re valuation is not colourable device-Reassessment is not valid-SLP of Revenue is dismissed. [S.10(2A), 45(3), 148, Art. 136]