ACIT v. Yes Bank Ltd. (2025) 303 Taxman 260 (SC) Editorial : Yes Bank Ltd v.ACIT (2024) 474 ITR 430 / 160 taxmann.com 329 (Bom)(HC)

S. 147 : Reassessment-With in four years-Bad debt-Provision for bad and doubtful debts-Schedule bank-Order of High Court quashing the reassessment notice and consequential order was quashed-SLP of Revenue is dismissed on account of delay of 162 days as well as on merits. [S. 36(1)(viia), 143(3), Art. 136]

Assessee-bank filed its return claiming deduction under section 36(1)(viia) on account of provision for bad and doubtful debts which was 7.5 per cent of profit of assessee.  Assessment was completed under section 143(3). Reassessment was initiated on writ the court quashed the reassessment proceedings on the ground that during original assessment proceedings Assessing Officer had called upon assessee to give details of outstanding balance in provision for bad and doubtful debts created under section 36(1)(viia),also a specific query was raised in respect of rural branches separately and called for proof of such rural branches. Reassessment notice and order disposing the objection was quashed. Revenue filed SLP against said impugned order, however, there was delay of 162 days in filing SLP which had not been satisfactorily explained.  SLP was to be dismissed on ground of delay as well as on merits.  (AY. 2010-11)

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