Court Rules Reassessment Invalid: No New Evidence, Just a Change of Opinion on Expense Classification.

The High Court examined the validity of reassessment proceedings regarding the treatment of certain expenditures as capital expenditure. The Court found that the Assessing Officer had already perused the books of accounts and formed a view that the expenses were revenue in nature, not capital. The Court also noted that during the initial assessment, the Assessing Officer independently analyzed the relevant materials provided by the petitioner. The Court highlighted that the reasons for reopening the case were based on the Audit Party's objections and not new facts. It emphasized that a change of opinion cannot be a valid reason for reassessment. Ultimately, the Court concluded that the reassessment was an attempt to revive an issue already addressed in the original assessment, rendering it unjustified. .....

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