The Bombay High Court held that reassessment proceedings initiated within four years were unsustainable where the issues sought to be reopened had already been examined during the original scrutiny assessment under S. 143(3). The Court found that the reasons recorded contained several factual inaccuracies (wrong dates, incorrect figures, and even a deduction under S. 80-IA which was never claimed), showing complete non-application of mind. Further, the foundation of reopening was based on findings which had already been reversed by the CIT(A), leaving no “reason to believe” that income had escaped assessment. The computation of book profit under S. 115JB and deductions under S. 36(1)(vii) and 36(1)(viia) were also matters already scrutinised earlier, and reopening on the same amounted to an impermissible review on a mere change of opinion. The order disposing of objections was also held defective as it failed to deal with the assessee’s objections and merely reproduced case law extracts without reasoning. Accordingly, the reassessment notice and the order rejecting objections were quashed. (AY 2016-17)