https://www.taxtmi.com/caselaws?id=793958 Reassessment based only on audit objections was held unsustainable where the same issues had already been specifically examined in the original scrutiny assessment. The reopening was within four years, so the first proviso to Section 147 did not apply, but the record showed prior queries and replies on deductions and depreciation claims, including Section 80G, Section 32AC, Section 35(2AB), software and goodwill depreciation, and related expenses. As the original assessment under Section 143(3) had considered those matters, the audit objection furnished no fresh tangible material and amounted to a mere change of opinion. The notice under Section 148 and the order disposing objections were quashed and set aside. en-us Mon, 15 Jun 2026 00:00:00 +0530 Fri, 26 Jun 2026 07:07:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793958 Reassessment based only on audit objections was held unsustainable where the same issues had already been specifically examined in the original scrutiny assessment. The reopening was within four years, so the first proviso to Section 147 did not apply, but the record showed prior queries and replies on deductions and depreciation claims, including Section 80G, Section 32AC, Section 35(2AB), software and goodwill depreciation, and related expenses. As the original assessment under Section 143(3) had considered those matters, the audit objection furnished no fresh tangible material and amounted to a mere change of opinion. The notice under Section 148 and the order disposing objections were quashed and set aside. Case-Laws Income Tax Mon, 15 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793958