Reopening of assessment u/s 147 - addition made on account of...

Reopening of assessment u/s 147 - addition made on account of loss on exchange rate difference - if the view of AO is accepted then the purchases would be booked at the time of RBI’s fixed rate and when actual payment will be made, the exchange rate difference would be less and the purchase cost would be increased by corresponding amount which is evident from the observation of AO as he has computed foreign exchange loss of ₹ 3.08 Crores in place of 1.91 Crores calculated by assessee. CIT(A) also held that the allegation of Assessing Officer is that assessee circulated black money is baseless and impounded. Thus, we do not find any infirmity or illegality in the order passed by ld. CIT(A), which we affirm accordingly. - Decided against revenue. - AT