2023 (8) TMI 1308 - SCH - Income Tax

Reopening of assessment u/s 147 - assessee has claimed deduction on account of notional foreign exchange loss - change of opinion - as per HC 2022 (4) TMI 624 - BOMBAY HIGH COURT reopening of assessment by the impugned notice dated 31.03.2021 is merely on the basis of change of opinion of the AO from that held earlier during the course of assessment proceedings. HELD THAT - There is an inordinate delay of 382 days in filing this special leave petition which has not been satisfactorily explained. Even on merits we do not find any good ground and reason to interfere with the impugned judgment. Accordingly the special leave petition is dismissed on the ground of delay and on merits. Pending application(s) if any also stand disposed of.

Summary

The Supreme Court dismissed the special leave petition due to an inordinate delay of 382 days in filing and found no good ground to interfere with the impugned judgment.