HC quashed assessment order passed merely on Change of Opinion

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

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