Reassessment on ground that HSBC didn't carry out any banking activities in Mauritius was mere change of opinion

IT/ILT : Where assessee during scrutiny assessment claimed benefit of DTAA between India and Mauritius and Assessing Officer accepted such claim making specific mention in order of assessment holding that assessee is entitled to benefit of DTAA since assessee was carrying on bonafide banking activities in Mauritius, Assessing Officer could not have re-opened assessment and re-examined issue on ground that assessee did not carry out bonafide banking activities in Mauritius.

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