Assessee-bank was merged with LCB in year 1985 and there was excess of liabilities over assets.  Consequently, assessee incurred loss and claimed same as deduction.  Assessing Officer disallowed same. Tribunal allowed the claim of the assessee. On appeal by Revenue  High Court  held that if no deduction was allowed on excess of liabilities over assets in year of merger, subsequent realization out of assets of LCB could not be brought to tax.  It further held that if such disallowance of loss had attained finality, matter required reconsideration and if found affirmative, no addition could be made in relevant assessment year.  (AY. 2007-08)