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HC quashed assessment order passed merely on Change of Opinion
Case Law Details
- Case Name
- Lehman Brothers Investments Pte.Ltd. Vs ACIT (Bombay High Court)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2015-16
- Courts
- All High Courts, Bombay High Court
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Lehman Brothers Investments Pte. Ltd. Vs ACIT (Bombay High Court)
Conclusion: Reopening of the assessment based on a different method of computation or application of the section was nothing else but a change of opinion as there was no failure to make a full and true disclosure ans the same was impermissible in law.
Held: Assessee was an investment holding company incorporated in Singapore. The ultimate holding company of assessee Lehman Brothers Holdings Inc. (“LBHI”) filed a petition under Chapter 11 of the U.S. Bankruptcy Code with the United States Bankruptcy Court for the Southern Dis...





