The Assessee being a nationalised bank had claimed deduction u/s 36(1)(viia) of the Act on account of provision for bad and doubtful debts which was allowed in original assessment order passed u/s 143(3) of the Act.  The AO thereafter issued a reopening notice against Assessee-bank on ground that an amount of loan repaid by Government to Assessee-bank on behalf of farmers under debt waiver scheme was liable to be brought to tax as said amount was already allowed as bad debt, and hence AO passed a reassessment order making addition on account of such amount of loan.  Assessee-bank contended that such amount being reimbursed by Government was only repayment of loan paid by Government instead of farmers and same could never be treated as income of Assessee-bank, hence, there was no new tangible material based on which assessment was reopened by AO.  The CIT(A) and Tribunal however referred the matter back to AO.  The High Court considering the above facts remanded the matter to the AO, stating that the Income-tax Act is a self-contained Act and this Court u/s 260A of the Act in its appellate jurisdiction, is not the proper forum for deciding mixed questions of fact and law, with a direction to AO to consider all the issues raised by the Assessee-bank, without being influenced by any of the observations made by the Tribunal, and pass orders afresh, after providing reasonable opportunity to the Assessee-bank.  (AY 2011-12)