TaxTMI 
TaxTMI 
2026 (6) TMI 834
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.... income on 30.11.2015. Along with said return of income, the petitioner enclosed the financial statement for financial year 2014-15. The assessing officer issued notice under Section 142(1) of the Income-Tax Act, 1961 (the I-T Act) calling upon the petitioner to provide the information requested for in the annexure thereto. Such information included details of large expenses claimed in the profit and loss account. The petitioner replied to said notice on 14.09.2018 providing the information requested for. In particular, the assessing officer was informed about the expenses debited in the profit and loss account towards net loss on foreign currency transactions and translation. Thereafter, original assessment order dated 28.01.2019 was issue....
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....5 needs to be disallowed while computing book profit u/s 115JB." The reassessment order was issued pursuant thereto. The petitioner had approached this Court prior thereto by challenging the notice under Section 148 and the order rejecting the objections raised by the petitioner with regard to reopening of the assessment. After the assessment order was issued upon reassessment, the prayer was amended to challenge such order. 3. Learned counsel for the petitioner referred to the notice under Section 142(1), the reply thereto and the financial statement of the petitioner. In particular, he invited my attention to Note 29 to the profit and loss account and to paragraph 2.10 of the Notes to financial statements for the year ended 31.03.20....
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....orresponds to assessment year 2015-16, along with the return of income. Note 29 to the profit and loss account records the net loss of foreign currency transactions and translation in a sum of Rs. 65,698,000. Paragraph 2.10 of the notes to financial statement reads as under: "2.10 Foreign currency transactions Foreign currency transactions are accounted at the exchange rates prevailing on the date of the relevant transactions. Exchange differences arising on foreign currency transactions settled during the year are recognized in the statement of profit and loss of the year. Monetary assets and liabilities denominated in foreign currencies as at the balance sheet date are translated at the closing exchange rates on that dat....
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....ls of large expenses claimed in the profit and loss account. By reply dated 14.09.2018, the assessee had provided such details. With specific reference to net loss on foreign currency transactions, the assessee had provided the details contained in Note-29 to the financial statement. 7. Thus, the documents on record disclose in no uncertain terms that the assessing officer had called for information pertaining to large expenses claimed in the profit and loss account and such information was provided by the assessee. The original assessment order was issued thereafter on 28.01.2019 without making any disallowance in relation thereto. As regards the second reason mentioned for reopening the assessment, namely, provision for warranty, said ....