https://www.taxtmi.com/caselaws?id=793706 Reassessment under Section 147 was held invalid where the original scrutiny assessment had already examined the disputed depreciation, goodwill, CSR deduction, unascertained liabilities, and additional depreciation claims, and no fresh tangible material emerged. Audit objections alone were treated as a change of opinion and not as jurisdictional material to reopen concluded proceedings. The Court also noted that the assessee's replies and disclosures had addressed these items during the original assessment, including the depreciation treatment for computers and computer software. The notice under Section 148 and the order rejecting objections were quashed, and the reassessment was held impermissible on all recorded grounds. en-us Mon, 15 Jun 2026 00:00:00 +0530 Mon, 22 Jun 2026 08:39:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793706 Reassessment under Section 147 was held invalid where the original scrutiny assessment had already examined the disputed depreciation, goodwill, CSR deduction, unascertained liabilities, and additional depreciation claims, and no fresh tangible material emerged. Audit objections alone were treated as a change of opinion and not as jurisdictional material to reopen concluded proceedings. The Court also noted that the assessee's replies and disclosures had addressed these items during the original assessment, including the depreciation treatment for computers and computer software. The notice under Section 148 and the order rejecting objections were quashed, and the reassessment was held impermissible on all recorded grounds. Case-Laws Income Tax Mon, 15 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793706