Reassessment based on audit objection alone was held unwarranted where no fresh tangible material supported reopening.

Reassessment under Section 147 of the Income-tax Act was held impermissible where it was initiated only on an audit objection and a reappraisal of the same record, without fresh tangible material or new information. Applying the settled reassessment framework, the Delhi High Court found the Revenue's challenge untenable and declined interference with the Tribunal's view that reopening was not justified. The Court also recorded that no question of law arose on the facts found, and the reassessment notice was unwarranted.

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Issues: Whether reassessment could be initiated merely on the basis of an audit objection without tangible material, and whether any question of law arose from the Tribunal's decision holding the reopening unwarranted.

Analysis: The reopening was founded on a reappraisal of the same record and on an audit objection, rather than on fresh tangible material or information. In light of the governing framework for reassessment under Section 147 of the Income-tax Act, 1961, as explained by the Supreme Court, such reopening was not permissible on the facts found by the Tribunal. The Court found the Revenue's challenge to be untenable and saw no basis to interfere with the concurrent conclusion that the reassessment was not justified.

Conclusion: No question of law arose. The reassessment notice was unwarranted, and the Revenue's appeal was dismissed.

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