TMI Blog1984 (7) TMI 222X X X X Extracts X X X X X X X X Extracts X X X X ..... ound that for these assessees in respect of the same assessment years there were decision of the Tribunal holding that the assets of the assessees have to be valued in a particular manner. In spite of it, the WTO on the basis of an Audit Note reopened the assessments and revalued the assets. The AAC found that such reassessments were untenable because a value different from that determined by the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ferent method it may be possible for him to value the assets at a higher figure. This is exactly a matter which is outside the scope of the reassessment proceedings as held by the Supreme Court in the case of CIT vs. Simon Carves Ltd. 1976 CTR (SC) 418 : (1976) 105 ITR 212 (SC). In the circumstances we find that the AAC was quite right in cancelling the reassessments. The appeals are, therefore, d ..... X X X X Extracts X X X X X X X X Extracts X X X X
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