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HC quashed reassessment notice under s.148 concerning lease payments, foreign currency transactions, and goodwill depreciation. Court found no valid grounds for reopening as lease transactions were consistently accepted since 2012-13, foreign currency claims were properly explained with unrealized gains/losses appropriately reflected in income computation, and goodwill depreciation claim was valid as s.43(6)(c) amendment denying such depreciation became effective only from 01.04.2021. AO's attempt to reopen assessment demonstrated mere change of opinion without fresh tangible material, failing to establish income escapement. Court held AO lacked jurisdiction to reopen assessment, ruling in assessee's favor.
HC quashed reassessment notice under s.148 concerning lease payments, foreign currency transactions, and goodwill depreciation. Court found no valid grounds for reopening as lease transactions were consistently accepted since 2012-13, foreign currency claims were properly explained with unrealized gains/losses appropriately reflected in income computation, and goodwill depreciation claim was valid as s.43(6)(c) amendment denying such depreciation became effective only from 01.04.2021. AO's attempt to reopen assessment demonstrated mere change of opinion without fresh tangible material, failing to establish income escapement. Court held AO lacked jurisdiction to reopen assessment, ruling in assessee's favor.
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