CIT v. Canara Bank (2023)456 ITR 316 (Karn)(HC)

S. 147 : Reassessment-After the expiry of four years-No allegation in notice that material facts necessary for assessment had not been disclosed-Reassessment notice and order is not valid. [S.148 260A]

Dismissing the appeal of the Revenue the Court held that the  Assessing Officer had not even stated in the notice of reassessment or alleged that there was failure on the part of the assessee to disclose fully and truly all the material facts necessary for the relevant assessment years. It was recorded in the file of the Assessing Officer that “on verification of the details” submitted by the bank, the Assessing Officer had noticed that certain branches which were reported to be situated in the rural area were not, in fact, situated in the rural area. The notice of reassessment is  not valid. Order of the Tribunal is affirmed. (AY.2006-07, 2007-08)