2023 (12) TMI 141 - SCH - Income Tax

Reopening of assessment u/s 147 - reason to believe - petitioner had claimed deduction on account of notional foreign exchange loss on non payment of imports - as decided by HC 2022 (4) TMI 625 - BOMBAY HIGH COURT As evident from the reasons for reopening that the Assessing Officer had all material facts before him when he made the original assessment. In the reasons for reopening there is not even a whisper as to what was not disclosed - This is a case wherein the assessment sought to be reopened on account of change of opinion - HELD THAT - The present special leave petition is belated and filed after a delay of 344 days. Even otherwise, we are not inclined to interfere with the impugned judgment. The application for condonation of delay and the special leave petition are accordingly dismissed. Pending application(s), if any, shall stand disposed of.

Summary

The Supreme Court of India dismissed a special leave petition filed after a delay of 344 days, stating they are not inclined to interfere with the impugned judgment. The application for condonation of delay was also dismissed.