Limited scrutiny and change of opinion challenge led to interim stay of reassessment proceedings pending further hearing.

Reassessment proceedings for assessment year 2016-2017 were challenged as being based on an audit objection and a change of opinion on material already examined in limited scrutiny. The petitioner's case was that the disputed issue had been considered in the original assessment, while the revenue sought time to file a counter affidavit. Pending further affidavits and hearing, the Court granted interim protection and stayed the reassessment proceedings for the time being, directing the matter to proceed after completion of pleadings.

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Issues: Whether reassessment proceedings initiated for the assessment year 2016-2017, said to rest on an audit objection and a change of opinion on the same material, should be stayed pending further consideration.

Analysis: The order records the petitioner's contention that the original assessment was completed on limited scrutiny and that the disputed issue had already been examined. It also notes the revenue's request for time to file a counter affidavit. Pending further affidavits and hearing, the Court granted interim protection.

Outcome: Reassessment proceedings were stayed in the meanwhile, and the matter was directed to proceed after filing of affidavits.

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