PCIT v. Punjab and Sind Bank. (2019) 108 taxmann.com 351 / 265 Taxman 538 ( Delhi) (HC) Editorial: SLP of revenue is dismissed, PCIT v. Punjab and Sind Bank. (2019) 265 Taxman 537 (SC)

S. 147 : Reassessment–Method of accounting-Full and true disclosure of all material facts regarding change in method of accounting in respect of Non-Performing Assets (NPAs) at time of assessment itself-Reassessment is held to be bad in law. [S. 145, 148]

AO initiated reassessment proceedings on ground that there was change of accounting method in respect of Non-Performing Assets (‘NPAs’)-Tribunal found that assessee had made full and true disclosure of all material facts regarding change in method of accounting at time of assessment.  Tribunal thus taking a view that precondition stipulated in first proviso to section 147 was not satisfied, set aside reassessment proceedings.  High Court upheld order passed by Tribunal. (AY. 2006-07)