The assessee claimed deduction for notional foreign exchange loss, which was examined in original assessment through queries and replies. Later AO reopened assessment on the ground that such loss was not allowable. The Court held reopening to be based on mere change of opinion since the issue was already scrutinized, and hence invalid. (AY. 2014-15)
Meer Gems v. ACIT [2023] 154 taxmann.com 646 (Bom)(HC) Editorial : SLP dismissed, ACIT v. Meer Gems [2023] 295 Taxman 120 (SC).
S. 147 : Reassessment-Change of opinion-Foreign exchange loss-Reopening on forex loss already examined earlier held invalid. [S. 37(1), 148, Art. 226]