https://www.taxtmi.com/caselaws?id=783576 Reassessment to withdraw allegedly excessive deduction under s 80HHC was challenged as a mere change of opinion and for lack of "reasons to believe." The HC held that although a scrutiny assessment under s 143(3) ordinarily carries a presumption of application of mind, that presumption arises only where there is some indication of pre-assessment enquiry or a speaking assessment dealing with the issue. Here, the assessment order and computation were wholly silent on s 80HHC and disclosed no material showing conscious consideration; hence, reopening was not based on a change of opinion but on a justified belief of excessive relief having been allowed. Jurisdiction under the reassessment provisions was upheld and the decision went in favour of the Revenue. en-us Thu, 11 Dec 2025 00:00:00 +0530 Thu, 18 Dec 2025 08:01:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783576 Reassessment to withdraw allegedly excessive deduction under s 80HHC was challenged as a mere change of opinion and for lack of "reasons to believe." The HC held that although a scrutiny assessment under s 143(3) ordinarily carries a presumption of application of mind, that presumption arises only where there is some indication of pre-assessment enquiry or a speaking assessment dealing with the issue. Here, the assessment order and computation were wholly silent on s 80HHC and disclosed no material showing conscious consideration; hence, reopening was not based on a change of opinion but on a justified belief of excessive relief having been allowed. Jurisdiction under the reassessment provisions was upheld and the decision went in favour of the Revenue. Case-Laws Income Tax Thu, 11 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783576