https://www.taxtmi.com/caselaws?id=798687 Reassessment cannot rest on a mere change of opinion where oil and gas exploration expenses and preliminary expenses were specifically examined during the original scrutiny assessment. Replies to the Assessing Officer's queries on the proposed reassessment issues, followed by acceptance without additions, demonstrate that the matters were considered. Failure to reproduce the original queries in an appellate order does not establish non-examination. Reopening on the same material merely because a different view is later taken is therefore invalid. en-us Mon, 07 Sep 2026 00:00:00 +0530 Thu, 10 Sep 2026 08:51:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798687 Reassessment cannot rest on a mere change of opinion where oil and gas exploration expenses and preliminary expenses were specifically examined during the original scrutiny assessment. Replies to the Assessing Officer's queries on the proposed reassessment issues, followed by acceptance without additions, demonstrate that the matters were considered. Failure to reproduce the original queries in an appellate order does not establish non-examination. Reopening on the same material merely because a different view is later taken is therefore invalid. Case-Laws Income Tax Mon, 07 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798687