9911796707
TMI Blog2017 (11) TMI 1893X X X X Extracts X X X X X X X X Extracts X X X X ..... truction of ₹ 100/- per sq.ft. as is noted in the reasons. There is no material, what to say of tangible material available on record to justify re-opening of the assessment. AO merely on assumption, presumption, recording vague and non-existing reasons, recorded the reasons for re-opening of the assessment which are not sufficient to validate the re-opening of the assessment in the matter. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the following grounds : 1. Whether on the facts and in the circumstances of the case, the Ld CIT(A) has erred by deleting the addition of ₹ 1,83,90524/- as assessee's share on account of profit generated from sale of property at Industrial Plot No.8, Phase-1, Industrial Area, Chandigarh having l/6th share in the property. 2. The ld. AR Shri Ashok Goyal appearing on behalf of the as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on record. The assessee in the facts of the present case, alongwith other co-owners had sold a property at Industrial Plot No. 8, Phase-I Industrial Area, Chandigarh for an amount of ₹ 22,00,00,000/- in which she had 1/6th share. The AO in the course of assessment proceedings also in the present case referred the matter to the DVO to ascertain the value of the asset as on 01.04.1981. Based u ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... per sq.ft. as is noted in the reasons. There is no material, what to say of tangible material available on record to justify re-opening of the assessment. The Assessing Officer merely on assumption, presumption, recording vague and non-existing reasons, recorded the reasons for re-opening of the assessment which are not sufficient to validate the re-opening of the assessment in the matter. Thus, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... notice u/s 148 and order of reassessment u/s 147 is liable to be quashed. Hence, the additional ground of appeal taken by the appellant is allowed. As the reassessment order has been quashed, the other grounds of appeal taken by the appellant become infructuous. 4.2 In the aforementioned peculiar facts and circumstances in the absence of any change in the material facts, we find no good reaso ..... X X X X Extracts X X X X X X X X Extracts X X X X
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