Reassessment proceedings were initiated solely on the basis of the audit objection. However, the record reveals that the AO had initially disagreed with the audit party and had accepted the assessee’s stand that the CSR expenditure voluntarily incurred was allowable as a business expenditure. As there is no independent application of mind by the AO at the time of issuing the notice under section 148 and the reopening was based merely on the audit objection, the reassessment notice was quashed by the High Court. SLP of the revenue dismissed. (AY. 2016-17)