Reassessment merely on DVO Report without AO’s Independent Inquiry was Invalid

Sahyog Corporation Vs ACIT (Gujarat High Court) Conclusion: AO must apply their own mind to the contents of the DVO report and any other available material as relying solely on a DVO’s report without any independent inquiry or satisfaction was a fundamental jurisdictional flaw that invalidated the entire reassessment proceeding from the start. Held: Assessee-firm filed a ‘nil’ income tax return for the Assessment Year 2018-19. AO received information regarding investments made by assessee in its two projects. AO referred the valuation of these investments to the DVO. DVO submitted a rep...