The assessment was completed u/s 143(3) of the Act. The reassessment notice was issued on the basis of Revenue Audit, though the two Assessing Officers have disagreed with the view of Revenue Audit. On writ allowing the petition the Court held that the opinion rendered by the audit party in regard to the law cannot, for the purpose of such belief, add to or colour the significance of such law. Therefore, the true evaluation of the law and its bearing on the assessment must be made directly and solely by the Income Tax Officer. Notice and order rejecting  the objection was quashed. Relied on  Indian and Eastern Newspaper Society v. CIT (19979) 119 ITR 996 SC)  IL  and FS Investment Managers Ltd v. ITO (2009) 298 ITR 32 (Bom)(HC).   (WP No. 3068 of 2019, dt 7-12-21) 

Grasim Industries Ltd. v. DCIT (Bom.)(HC)(UR)