https://www.taxtmi.com/caselaws?id=758729 The Gujarat HC ruled in favor of the assessee regarding reopening of assessment under Section 147. The AO had issued notice within four years for an assessment previously completed after scrutiny, questioning deduction of foreign exchange loss. The court held that during regular assessment, the AO had already examined the petitioner's claim for foreign exchange loss deduction and received justifications. Without new tangible material, the AO could not reopen assessment merely based on change of opinion. The succeeding AO cannot correct legal errors made during original scrutiny assessment. The reopening was invalid as it was based on correcting previous opinion rather than new information. en-us Thu, 05 Sep 2024 00:00:00 +0530 Wed, 18 Sep 2024 07:53:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=758729 The Gujarat HC ruled in favor of the assessee regarding reopening of assessment under Section 147. The AO had issued notice within four years for an assessment previously completed after scrutiny, questioning deduction of foreign exchange loss. The court held that during regular assessment, the AO had already examined the petitioner's claim for foreign exchange loss deduction and received justifications. Without new tangible material, the AO could not reopen assessment merely based on change of opinion. The succeeding AO cannot correct legal errors made during original scrutiny assessment. The reopening was invalid as it was based on correcting previous opinion rather than new information. Case-Laws Income Tax Thu, 05 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=758729