Reassessment notice was issued on the basis that there was difference in valuation. On writ the Court held that the assessee had disclosed all facts truly and fully during course of regular assessment and Assessing Officer had issued notice under section 148 on borrowed satisfaction. The notice and order disposing the objection is quashed. (AY. 2012-13)
Kunal Kiran Sheth v. ACIT (2023) 295 Taxman 292 (Guj.)(HC)
S. 147 : Reassessment-After the expiry of four years-Capital gains-Slump sale-Borrowed satisfaction-Difference in valuation-No failure to disclose material facts-Reassessment notice and order disposing the objection is quashed and set aside. [S. 45, 54EC, 148, 154, Art. 226]