1984 (1) TMI 43

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..... ed under s. 59 of the E.D. Act, 1953. One, Kasturbai Chandrasen Ashar, died on October 11, 1975. Her husband as the accountable person submitted an account for the purposes of estate duty to the Department. The estate included 81 shares of the International Cotton Corporation (P) Ltd., a private limited company. Based upon a valuation report, the value of these shares was shown at the rate of Rs .....

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..... 11, 1980, the chartered accountants of the petitioners asked the Asst. Controller for particulars as to why the notice had been issued. There was no response. On August 14, 1980, this petition was filed by the sons of Kasturbai and her late husband impugning the notice. There is no affidavit in reply, but a copy of the reasons recorded by the Asst. Controller for reopening the assessment has bee .....

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..... n by the revenue audit, the Asst. Controller changed his opinion as to the details of the valuation of the shares of the private limited company, and such change of opinion does not constitute information within the meaning of the section. The notice, accordingly, must be set aside. The petition is made absolute in terms of prayer (a) of the petition, with costs. Rule accordingly. - - TaxTMI .....

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