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    <title>2023 (12) TMI 770 - MADRAS HIGH COURT</title>
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    <description>The HC ruled in favor of the assessee, quashing the reopening of assessment under Section 147 of the Income Tax Act, 1961. The court found that the petitioner company had made complete disclosure of foreign exchange transactions in its profit and loss account and returns filed under Section 139. The assessing officer&#039;s attempt to reopen the completed assessment was based merely on a change of opinion by a subsequent officer, which courts have consistently deprecated. Despite allegations of window dressing, the court noted there was no case of non-disclosure of material facts, as the company had no accumulated losses and properly disclosed all relevant information in its financial statements and tax returns.</description>
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    <pubDate>Fri, 17 Nov 2023 00:00:00 +0530</pubDate>
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      <title>2023 (12) TMI 770 - MADRAS HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=447086</link>
      <description>The HC ruled in favor of the assessee, quashing the reopening of assessment under Section 147 of the Income Tax Act, 1961. The court found that the petitioner company had made complete disclosure of foreign exchange transactions in its profit and loss account and returns filed under Section 139. The assessing officer&#039;s attempt to reopen the completed assessment was based merely on a change of opinion by a subsequent officer, which courts have consistently deprecated. Despite allegations of window dressing, the court noted there was no case of non-disclosure of material facts, as the company had no accumulated losses and properly disclosed all relevant information in its financial statements and tax returns.</description>
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