Reopening of Assessment Not Permissible for Change of Opinion

Skoda Auto Volkswagen India Private Limited Vs ACIT (Bombay High Court) Petitioner had in its annual report mentioned about the technical know how fee, royalty and technical assistance fee that it had paid to Skoda Auto a.s. and Volks Wagen AG. Petitioner had also filed Form 3CEB in which it had disclosed about details and description of international transactions in respect of know how and patents and it had disclosed the details regarding royalty paid and lump sum fees for know how paid to Skoda Auto a.s. and fees for technical services paid to Volks Wagen AG. Before the original assessment ...