Dismissing the appeal of the Revenue the Court held that the Assessing Officer had not even stated or alleged that there was failure on part of assessee to disclose fully and truly all material facts necessary for said assessment years in respect of claim of deduction under section 36(1)(viia), Tribunal rightly held that reopening assessment initiated beyond four years was bad in law.(AY. 2006-07, 2007-08)
CIT v. Canara Bank (2023) 155 taxmann.com 289/ 456 ITR 316 (Karn)(HC) Editorial: SLP of Revenue is dismissed, CIT v. Canara Bank (2023) 295 Taxman 228/(2024) 460 ITR 6 (SC)
S. 147 : Reassessment-After the expiry of four years-Bad debt-Provision for bad and doubtful debts-Schedule bank-No failure to disclose material facts-Order of the Tribunal is affirmed. [S. 36(1)(viia), 148, 260A]