District Co-operative Central Bank Ltd. v. ACIT (2021) 190 ITD 105 (Bang.)(Trib.)

S. 147 : Reassessment-With in four years-Change of opinion-Provision for bad and doubtful debts-Reassessment notice was held to be not valid. [S. 36(1)(viia), 148]

Allowing the appeal the Tribunal held that the Assessing Officer had called for all details in respect of provision made for bad debts during original scrutiny assessment proceedings and after considering details he had accepted claim. Reassessment notice was  on mere change of opinion  hence set aside.  (AY. 2012-13)