Reopening of assessment u/s 147 - Disallowance of CSR amount u/s...

Reopening of assessment u/s 147 - Disallowance of CSR amount u/s 37(2) - reason to believe or suspect - tangible material to reopen - AO power to review not to be confused with the power to re-assess - The petitioner argued that the notice was based on a change of opinion and lacked fresh tangible material. They also contested the treatment of CSR expenses and claimed that their practice was lawful. The High Court ruled in favor of the petitioner, holding that the notice for reopening the assessment was invalid and unsustainable, and the treatment of CSR expenses was permissible under the law. - The Court agreed with the petitioner's contention that donations made to eligible trusts, even if funded by CSR, qualified for deduction under Section 80G of the Act