Company wins challenge against reassessment notice for exempt income expenditure disallowance under section 14A Rule 8D

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....HC quashed reassessment notice issued under section 14A read with Rule 8D for disallowance of expenditure relating to exempt income. Petitioner-company had originally provided complete details regarding exempt income and investments during regular assessment proceedings, with no disallowance made. AO's reopening was based solely on verification of profit and loss account and balance sheet without any fresh tangible material. Court held that reassessment cannot be initiated on mere change of opinion regarding same set of facts previously considered. Respondent failed to address petitioner's objection regarding delayed reply beyond sixty-day period. Reassessment proceedings constitute impermissible review of original assessment order passed under section 143(3). Petition allowed in favor of assessee.....