https://www.taxtmi.com/caselaws?id=290719 Reassessment initiated on the basis of an audit objection and an alleged excess claim of pre-operative expenses was found invalid because the reasons recorded were a verbatim reproduction of the audit objection. The Assessing Officer had not formed an independent satisfaction; the reopening was based on borrowed satisfaction from the audit party. As no fresh tangible material emerged and the original assessment had already examined the claim, reopening on the same material amounted to a mere change of opinion, which is impermissible. The reassessment notice and all consequent proceedings were quashed in favour of the assessee. en-us Tue, 15 Jan 2019 00:00:00 +0530 Tue, 13 Oct 2020 11:43:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=290719 Reassessment initiated on the basis of an audit objection and an alleged excess claim of pre-operative expenses was found invalid because the reasons recorded were a verbatim reproduction of the audit objection. The Assessing Officer had not formed an independent satisfaction; the reopening was based on borrowed satisfaction from the audit party. As no fresh tangible material emerged and the original assessment had already examined the claim, reopening on the same material amounted to a mere change of opinion, which is impermissible. The reassessment notice and all consequent proceedings were quashed in favour of the assessee. Case-Laws Income Tax Tue, 15 Jan 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=290719