https://www.taxtmi.com/caselaws?id=754928 The HC quashed reassessment proceedings initiated by the revenue department against a company. The court held that the AO had already examined all books of accounts, bills and vouchers during original assessment proceedings dated 28.03.2016 and formed independent views on treating perfume pump imports as revenue expenditure and allowing deduction for damaged goods under section 80IC. The reassessment was based on borrowed satisfaction from the Audit Party rather than independent application of mind by the AO, using the same material previously considered. The court ruled that reopening cannot be done without new facts coming to the AO's knowledge post-original assessment, as this would constitute mere change of opinion, which is impermissible under law. en-us Tue, 25 Jun 2024 00:00:00 +0530 Tue, 02 Jul 2024 12:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754928 The HC quashed reassessment proceedings initiated by the revenue department against a company. The court held that the AO had already examined all books of accounts, bills and vouchers during original assessment proceedings dated 28.03.2016 and formed independent views on treating perfume pump imports as revenue expenditure and allowing deduction for damaged goods under section 80IC. The reassessment was based on borrowed satisfaction from the Audit Party rather than independent application of mind by the AO, using the same material previously considered. The court ruled that reopening cannot be done without new facts coming to the AO's knowledge post-original assessment, as this would constitute mere change of opinion, which is impermissible under law. Case-Laws Income Tax Tue, 25 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754928