ORDER :

1. Having examined the record, we find that in this case, the Department sought reopening of the assessment based on the opinion given by the District Valuation Officer (DVO).

2. Opinion of the DVO per se is not an information for the purposes of reopening assessment under Section 147 of the Income Tax Act, 1961. The AO has to apply his mind to the information, if any, collected and must form a belief thereon.

3. In the circumstances, there is no merit in the Civil Appeal. The Department was not entitled to reopen the assessment.

4. Civil appeal is, accordingly, dismissed.

No order as to costs.

Appeal dismissed.