Assessee entitled to raise objections u/s 264 and 246A even if not raised during original assessment proceedings

R.C. Kannan Vs PCIT (Madras High Court) Conclusion: AO had to therefore refer the valuation of the property viz., capital asset under proviso to sub-clause (vii)(c) to sub-section 2 to Section 56 of the IT Act to the Valuation Officer. Even if, no objections was raised before AO prior to the assessment order being passed, assessee would still be entitled to raise such objections both before the Revisional Authority under Section 264 of the IT Act or before the Appellate Commissioner under Section 246A of the IT Act as these proceedings are continuation of the original assessment proceedings. H...