https://www.taxtmi.com/highlights?id=96958 Reopening of assessment based solely on an audit party's objection does not satisfy the statutory 'reason to believe' required for reassessment; the audit objection is characterised as an expert opinion and its reliance amounts to a mere change of opinion. The assessing officer's prior detailed scrutiny and disallowance of exemption under Section 80-IA after threadbare inquiry precluded invoking reassessment provisions where the same issue had been considered from all conceivable angles. Where omission arose from the AO's inability to envisage a point, that does not confer power to reopen under reassessment provisions; the departmental remedy available was power of revision rather than reassessment. en-us Tue, 17 Feb 2026 10:14:26 +0530 Tue, 17 Feb 2026 10:14:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=96958 Reopening of assessment based solely on an audit party's objection does not satisfy the statutory 'reason to believe' required for reassessment; the audit objection is characterised as an expert opinion and its reliance amounts to a mere change of opinion. The assessing officer's prior detailed scrutiny and disallowance of exemption under Section 80-IA after threadbare inquiry precluded invoking reassessment provisions where the same issue had been considered from all conceivable angles. Where omission arose from the AO's inability to envisage a point, that does not confer power to reopen under reassessment provisions; the departmental remedy available was power of revision rather than reassessment. Highlights Income Tax Tue, 17 Feb 2026 10:14:26 +0530 https://www.taxtmi.com/highlights?id=96958