Meer Gems v. ACIT (2023) 154 taxmann.com 646 (Bom)(HC) Editorial : SLP of Revenue is dismissed, ACIT v. Meer Gems (2023) 295 Taxman 120 (SC)

S. 147 : Reassessment-After the expiry of four years-Notional foreign exchange loss-No failure to disclose material facts-Change of opinion-Notice and order disposing the objection is quashed.[S.37(1), 148, Art. 226]

Allowing the petition the Court held that hat there was a query raised regarding details of foreign exchange loss during original assessment which had been provided by assessee through CA’s letters. Since  the issue of foreign exchange loss was a subject matter of consideration of Assessing Officer during original assessment, reopening of assessment was based merely on change of opinion and hence not sustainable. (AY. 2014-15)