Assessee-company filed its return declaring a loss of Rs. 10.24 crores-Case was selected for scrutiny and an assessment under section 143(3) was completed. During scrutiny, Assessing Officer specifically called for details of salary/remuneration and legal/professional expenses, and assessee furnished Employment Agreement of its Managing Director and Consulting Agreement of a shareholder, covering payments of Rs. 8.90 crores and Rs. 90.81 lakhs, respectively .Assessing Officer thus had these documents, though no specific finding on these expenses was recorded in assessment order. Thereafter, Assessing Officer issued a notice under Section 148A(b) enclosing local Audit Party objections alleging escapement on account of incorrect allowance of expenses aggregating about Rs. 9.81 crores (the above payments) . On writ the Court held that   reopening assessment on basis of objections of Audit Party, shall in above facts, amount to reviewing assessment already made, as relevant material was available with Assessing Officer during that assessment . Court also held that  it  is necessary to draw a distinction between a case where assessee failed to provide some material/information during assessment, which was flagged by Audit Party, as against a case where all information was provided by assessee, but was not considered or commented upon by Assessing Officer in assessment order, resulting in a subsequent audit objection. Latter cannot be the subject matter of reassessment, as it shall have the effect of reconsidering the same material to arrive at a different conclusion, which cannot be permitted. Therefore, reassessment notice and consequential orders were quashed and set aside. Court also held that the notice under section 148 had been issued on 31-3-2023, which was beyond said period of four years; therefore, in view of first proviso to section 149, no notice could have been issued under section 148, as no such notice could have been issued under provisions that were in force prior to1-4-2021. Accordingly, notice dated 31-3-2023 and subsequent proceedings being barred by limitation were quashed and set aside. (AY.  2016-17)