Assessee, a power generation company, filed its return claiming exemption under section 80-IA. Assessing Officer disallowed the exemption after detailed examination in the original assessment. Subsequently, an audit party raised an objection stating that proportionate corporate expenses had been wrongly added back to profits. On the basis of the same, the Assessing Officer initiated reassessment proceedings and passed an order raising a demand. On appeal, the Tribunal held that the  Assessing Officer had already conducted a threadbare inquiry and disallowed exemption under section 80-IA on different counts. Initiation of reassessment proceedings on the basis of the audit party’s objection or opinion could at best be construed to be an opinion of an expert and, thus, reassessment proceedings were nothing more than a change of opinion. The order passed by the Tribunal did not suffer from any illegality. (AY. 2011-12, 2012-13)