AO Cannot Reopen Old Assessments Based on Future Amendment Banning Goodwill Depreciation Without ‘Reasons to Believe

GTPL Hathway Limited Vs DCIT Circle 2(1)(1) & Anr. (Gujarat High Court) Conclusion: Since reasons recorded by AO to form prima facie conclusion that there was likelihood of any gain on account of revenue expenses incurred by assessee was also without any basis in the absence of any fresh tangible material available with the respondent AO as the fact remained that assessee had unrealized gain and unrealized loss which was not claimed and duly reflected in the computation income as assessee had claimed only bank charges expenditure for hedging of foreign currency. AO had no reason to believe...