Allowing the petition the Court held that, there was no failure to disclose material facts and specific query was raised in the course of original assessment proceedings. Not discussing in the assessment order cannot be ground for reopening of the assessment. Notice for reassessment and order disposing the objection is quashed. (AY. 2014-15)
DCB Bank Ltd. v. Dy. CIT (2023) 458 ITR 716 /295 Taxman 387 (Bom.)(HC)
S. 147 : Reassessment-After the expiry of four years-Bad debts written off-Book profit-Exempt income-No failure to disclose material facts-Reassessment notice and order disposing the objection is quashed. [S.14A, rt. 36(1)(vii), 44AB,115JB, 148, Art. 226]