Case Law Details
DCIT Vs East West Pipeline Private Limited (ITAT Mumbai)
ITAT Mumbai held that initiation of reassessment proceedings on account of change of opinion formed on re-appraisal of the facts already on record and examined during the regular assessment proceedings is liable to be quashed.
Facts- The Assessee is a private limited company engaged in the business of transportation of natural gas through cross country pipeline network.
The case of the Assessee for A.Y. 2015-15 was selected for regular scrutiny and the Assessing Officer completed the assessment u/s. 143(3) of the Act vide order, dated 23/12/2016. Subsequently, after the lapse of 4 years from the end of A.Y. 2014-15, reassessment proceedings were initiated u/s. 147 of the Act by issuance of notice dated 30/03/2021. AO vide order dated 29/03/2022 made addition of INR 602,95,70,778/- disallowing loss pertaining to Cross Currency Swap Contracts (CCS) debited to Profit & Loss Account by the Assessee during the relevant previous year.
CIT(A) quashed the assessment order. Being aggrieved, revenue has preferred the present appeal.
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