2025 (1) TMI 1495

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.... challenged the impugned speaking order dated 24.01.2022 passed by the second respondent and a Notice that preceded the impugned order under Section 148 of the Income Tax Act, 1961 dated 26.03.2021 for the Assessment Year 2016-2017. 2. The dispute pertains to the Assessment Year 2016-2017. The petitioner had filed return of income on 29.11.2016 under Section 139(1) of the Income Tax Act, 1961 which was scrutinised and ultimately the Assessment was completed on 17.12.2018. After the Assessment order was passed on 17.12.2018, the impugned notice dated 26.03.2021 was issued under the old regime as it stood prior to 01.04.2021. The reasons for issuance of the impugned notice dated 26.03.2021 as communicated to the petitioner which reads as u....

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....Ended 31st March 2016   Notes 2015-2016 Rs 2014-2015 Rs.   Revenue from operations Sales and other operating income 15 12,805,297,824 13,495,188,484   Other Income 16 50,650,764 40,312,641     Total 12,855,948,588 13,535,501,125   Expenses         Purchase of Stock in Trade 17 11,784,361,705 12,365,177,004   Changes in Inventories 17 13,986,188 176,794,574   Employee Benefits Expense 18 242,565,731 225,233,992   Other Expenses 19 506,812,448 441,342,833     Total 12,519,753,696 13,208,548,403   Finance Costs ....

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....fit or loss on account of exchange difference between the date of transaction and on settlement is recognised in the Statement of Profit and Loss. Monetary liabilities/assets related to foreign currency transaction remaining unsettled at the end of the year are translated at the year-end rate. The company uses foreign exchange forwards and currency option contracts to hedge its risk associated with foreign currency fluctuations relating to certain firm commitments. Premium or Discount on the contracts are amortized and recognised in the Statement of Profit and Loss over the period of the contract. Forward exchange contract outstanding at the balance sheet date are stated at the yearend rate and any gains or losses are recognised in....

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.... petitioner was correct or not. 10. I have considered the arguments advanced by the learned counsel for the petitioner and the learned Standing Counsel for the respondents and the learned Senior Standing Counsel for the respondents. 11. A reading of the documents that have been filed before this Court which have been referred to supra indicates that all the informations that were required for completing the Assessments were furnished by the petitioner in response to specific notices issued to the petitioner under Section 143(2) of the Income Tax Act, 1961. 12. Specifically, information relating to Foreign Currency transactions and the loss based on which the expenses was claimed as the deduction under Section 37 of the Act was clai....