Reassessment proceedings initiated merely on the basis of an audit objection that assessee had not disallowed the entire amount of CSR expenditure, which resulted in under assessment of tax, without independent formation of belief by the AO. Since Assessing Officer earlier himself disagreed with objections of the audit party on the ground that assessee-company was not required to incur any CSR expenses as per section 135 of the Companies Act, 2013, and CSR expenses incurred voluntarily would be allowable expenses, the reopening notice was to be set aside. It was laid down that reopening under section 147 founded solely on audit objection amounts to an impermissible review/change of opinion and fails to satisfy the statutory requirement of ‘reason to believe’. Consequently, notice under section 148 and all consequential proceedings were declared legally unsustainable. Revenue’s SLP dismissed.(AY. 2016-17)