Audit Objection Triggers Reopening of Assessment u/s 147; Change of Opinion on Forex Gains for 2014-15.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Validity of reopening of assessment u/s 147 - A copy of the audit objection reveals that because for the subsequent year, i.e., AY 2014- 15, the Department had not accepted assessee’s contention and added back the foreign exchange gain after treating it as revenue receipt, to take a consistent stand on the same issue, the Assessment has to be reopened. From this communication also, it is quiet clear that there has not been non-disclosure of any material fact but only change of opinion. - HC....