ACIT v. Meer Gems (2023) 295 Taxman 120 (SC) Editorial: Meer Gems v. ACIT (2023) 154 taxmann.com 646 (Bom)(HC)

S. 147 : Reassessment-After the expiry of four years-Notional foreign exchange loss-No failure to disclose material facts-Change of opinion-Order of High Court is affirmed-SLP of Revenue is dismissed.[S.37(1), 148, Art. 136]

Reassessment notice was challenged before the High Court on the ground that since issue of foreign exchange loss was a subject matter of consideration of Assessing Officer during original assessment, reopening of assessment was based on merely change of opinion and thus not sustainable.  SLP filed against  the order of High Court is  dismissed.  (AY. 2014-15)