Assessee-company had not carried on any business for 24 years as manufacturing activities having been closed down. Assessee had claimed several business expenditure such as maintaining skilled staff for keeping machinery intact, minimum amounts to be paid for retaining electricity connection and so on incurred for those years when there was no business. AO allowed same.-Later on, AO issued a reopening notice on ground that since assessee was not carrying on any business for several years, there could be no claim for business expenses. Tribunal allowed the appeal of the assessee. On appeal by the revenue the Court held that since assessee had no intention to close down business and was keeping machinery read for use and after 24 years assessee had also commenced its manufacturing activity, all these expenses incurred by assessee were wholly and exclusively for purpose of business and, thus, same were to be allowed.  Reassessment notice is held to be bad in law due to change of opinion. Vacancy allowance which was not claimed in the original assessment proceedings cannot be claimed in reassessment proceedings.  (Arising from  Punalur Paper Mills Ltd. v ITO  (2009) 29 SOT 449 (Cochin) (Trib)  (ITA Nos. 1378 to 1423 of 2019 dt 7 -02 -2019)     (AY.1996-97 to 2002-03  2004-05)