https://www.taxtmi.com/caselaws?id=795013 Reassessment denying a deduction for a port infrastructure facility was impermissible because the undertaking's ownership, development through cranes and capital investment, lease arrangements, and deduction claim had been fully disclosed and examined in the original scrutiny assessment. Foreign shareholding in the Indian-registered assessee did not breach the ownership condition. As no new tangible material emerged, the recorded reasons reflected only a change of opinion, and a reopening based solely on a Revenue audit objection could not stand. The reopening notice, rejection of objections, show-cause notice, and draft assessment order were quashed. en-us Mon, 06 Jul 2026 00:00:00 +0530 Wed, 15 Jul 2026 15:22:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795013 Reassessment denying a deduction for a port infrastructure facility was impermissible because the undertaking's ownership, development through cranes and capital investment, lease arrangements, and deduction claim had been fully disclosed and examined in the original scrutiny assessment. Foreign shareholding in the Indian-registered assessee did not breach the ownership condition. As no new tangible material emerged, the recorded reasons reflected only a change of opinion, and a reopening based solely on a Revenue audit objection could not stand. The reopening notice, rejection of objections, show-cause notice, and draft assessment order were quashed. Case-Laws Income Tax Mon, 06 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795013