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

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