Section 148 notice unsustainable as very basis of notice was invalid

Aberdeen Asia Pacific Including Japan Equity Fund Vs DCIT (Bombay High Court) The issue under consideration is whether the notice u/s 148 issued by AO for re-opening of assessment is justified in law? In the present case, AICFL was set up as a Trust under the laws of the State of Delaware, USA has been organised for the purpose of investing and dealing in all securities and instruments across the world. Because of popularity of the LLC regime e., Limited Liability Company across the investment funds industry, AICFL was re-organized / converted from a Trust into a Limited Liability Company (LLC...