Reopening of a completed scrutiny assessment is invalid where...

Reopening of a completed scrutiny assessment is invalid where tax deducted at source on salary payments was not claimed as expenditure or as a statutory deduction, but was mistakenly treated as claimed through a misreading of the tax audit report. Where the deduction position and tax withholding had already been examined and accepted during original scrutiny, reopening on the same material without fresh tangible material constitutes an impermissible change of opinion and demonstrates non-application of mind. The reassessment notice and consequential order were quashed.