Tax Officer Cannot Reopen Settled Share Valuation Case U/s 147 When Property Details Were Previously Examined

HC quashed reassessment proceedings initiated under s.147 regarding alleged undervaluation of shares of TREPL. AO's attempt to reopen assessment was based on the value of immovable property (Friends Colony) held by TREPL, an issue previously examined in earlier reassessment proceedings. Petitioner had already demonstrated through audited financial statements that TREPL owned only two floors of the property, which AO had accepted. The court found that reopening the same issue violated procedural requirements under s.148A(d), as AO failed to consider petitioner's response to s.148A(b) notice and the existing record. Since the information was previously scrutinized and no credible contradictory evidence existed, reassessment was held invalid. .....

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