Reassessment Invalid: Officer Can't Reclassify Examined Expenditures as Capital Based on Audit Opinion.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Validity of reopening of assessment - Entire attempt of the assessing officer was to hold that the expenditure incurred, in respect of which details are already available on record and was examined in original assessment, as capital expenditure and such opinion is solely based out of the opinion of the audit party, which in itself is not permissible. The reassessment is bad in law - AT....