https://www.taxtmi.com/caselaws?id=312683 Gujarat HC quashed reopening of assessment under Section 147. The petitioner had average net losses of Rs. 187.67 crores over three preceding financial years, thus not obligated to spend on CSR under Section 135. The expenditure was commercial and allowable under Section 37(1). The court found reopening was based on audit party objection without tangible material and constituted impermissible change of opinion, as detailed scrutiny was already conducted without additions or disallowances in original assessment. en-us Wed, 19 Apr 2023 00:00:00 +0530 Fri, 01 Mar 2024 18:03:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=312683 Gujarat HC quashed reopening of assessment under Section 147. The petitioner had average net losses of Rs. 187.67 crores over three preceding financial years, thus not obligated to spend on CSR under Section 135. The expenditure was commercial and allowable under Section 37(1). The court found reopening was based on audit party objection without tangible material and constituted impermissible change of opinion, as detailed scrutiny was already conducted without additions or disallowances in original assessment. Case-Laws Income Tax Wed, 19 Apr 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=312683