Infosys Limited vs The Deputy Commissioner Of Income Tax on 17 June, 2019
27. The Division Bench of this Court in the case
of Commissioner of Income Tax & another Vs.
Hewlett-Packard Globalsoft Pvt. Limited3, while
considering the substantial question of law that,
Whether on the facts and circumstances of the case, the
Tribunal was correct in holding that the reopening of
assessment is by mere change of opinion, without
appreciating the fact that the expenditure related to on-
site development of computer software was not
3
(2016)380 ITR 386 (Kar)