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2019 (2) TMI 1580 - HC - Income TaxReopening of assessment - Assessment order passed u/s 143(3)- tangible material - audit objection - amount claimed on account of forex gain not allowable expenditure being revenue in nature - HELD THAT:- Following Kelvinator (2010 (1) TMI 11 - SUPREME COURT OF INDIA) decided by the Supreme Court held that change of opinion is impermissible. Revenue clearly barred by provisions of Section 147/148 of the Act. In view of the above discussion, the impugned re-assessment notice dated 30.03.2017, cannot be sustained. It is hereby quashed; all consequential proceedings issued and conducted pursuant to the said re-assessment notice are also hereby quashed. - Decided in favour of assessee.
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