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Reassessment merely on DVO Report without AO’s Independent Inquiry was Invalid
Case Law Details
- Case Name
- Sahyog Corporation Vs ACIT (Gujarat High Court)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
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- Courts
- All High Courts, Gujarat High Court
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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. DV...







