https://www.taxtmi.com/caselaws?id=448669 ITAT Mumbai dismissed Revenue's appeal challenging CIT(A)'s order quashing reassessment proceedings under Section 147. The assessee company had fully disclosed primary facts regarding foreign exchange loss claims during original assessment, where AO accepted deduction of INR 604.35 crores. Reassessment was initiated after 4 years based on reappraisal of same facts without new material, constituting impermissible change of opinion. ITAT held that since assessee made full disclosure and no failure existed, reassessment beyond 4 years was invalid under First Proviso to Section 147. The tribunal upheld CIT(A)'s decision quashing the assessment order. en-us Fri, 05 Jan 2024 00:00:00 +0530 Thu, 25 Jan 2024 15:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448669 ITAT Mumbai dismissed Revenue's appeal challenging CIT(A)'s order quashing reassessment proceedings under Section 147. The assessee company had fully disclosed primary facts regarding foreign exchange loss claims during original assessment, where AO accepted deduction of INR 604.35 crores. Reassessment was initiated after 4 years based on reappraisal of same facts without new material, constituting impermissible change of opinion. ITAT held that since assessee made full disclosure and no failure existed, reassessment beyond 4 years was invalid under First Proviso to Section 147. The tribunal upheld CIT(A)'s decision quashing the assessment order. Case-Laws Income Tax Fri, 05 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448669