The assessee filed its original return of income in October 2007 and revised it in March 2009, claiming a deduction of ₹69,88,37,464 for inventories, sundry debtors, loans & advances, and cost of set-top boxes written off against the share premium account pursuant to an amalgamation scheme approved by the Bombay High Court. The case was selected for scrutiny, and the AO passed an assessment order under Section 143(3) on 30.12.2009, disallowing ₹1,00,41,557 on account of bad debts. The assessee’s total income was assessed as NIL after adjusting unabsorbed business losses and depreciation. On 30.03.2012, the AO issued a notice under Section 148, stating that the assessee had claimed deductions for amounts already adjusted against the share premium account, resulting in an alleged double deduction of ₹69,88,37,464. The reasons for reopening were provided in May 2012. The assessee filed objections in November 2012, arguing that the issues had already been examined during the original assessment and the reassessment was based on a change of opinion, which is impermissible under the Income Tax Act. he further added that there was no actual double deduction and the AO failed to provide the date of recording reasons, making the reassessment invalid. The AO rejected the objections in January 2013, thus, the assessee challenged the reassessment before the Bombay High Court. The High Court quashed the reassessment notice under Section 148, holding that the same issues were already examined during the original scrutiny assessment, and the reassessment amounted to a change of opinion, which is not valid. It further held that failure to discuss an issue in the assessment order does not mean it was not considered, if the AO raised queries and accepted the assessee’s response, reopening on the same issue is not justified and no failure to disclose material facts was demonstrated. The court also added that the AO did not rebut the assessee’s objection that no double deduction occurred, which indicated a lack of valid reasoning for reopening and the claim was a balance sheet adjustment and not a profit and loss account deduction, making the AO’s reasoning flawed. Accordingly, the court quashed and set aside the reassessment notice for AY 2007-08 and the order disposing the objection.  (WP No. 649/2013, dated 20.02.2025) (AY. 2007-08)