The Tribunal held that the matters which are subject matter of appeal, reference or revision cannot be reopened . Followed Writ Petition (for AY 2003-04) No. 1765 of 2011 dated 09/11/2011 in assesses own case .(AY. 2004 -05)
Dy. CIT v. ICICI Bank Ltd ( 2019)202 TTJ 560 / ( 2020) 185 DTR 233 (Mum) (Trib)
S.147: Reassessment – Subject matter of appeal- Merger – Bad debt – Matters which are subject matter of appeal, reference or revision cannot be reopened [ S. 36(1)(vii) ,37(1) , 148, 251 ]