Allowing the petition the Court held that , the audit information was merely an information and that change of opinion was impermissible. The reassessment notice was solely based on audit opinion. (AY.2011-12)
FIS Global Business Solutions India Pvt. Ltd. v. CIT (2018) 409 ITR 560 (Delhi)(HC)
S.147:Reassessment —with in four years- Change of opinion -Opinion of revenue Audit party- Foreign Exchange Fluctuation gain on interest income is not allowable — Notice for reassessment is held to be invalid [ S.148 ]