Sec 147 Reopening After 4 Years Invalid; Audit Objection Not Tangible; Bad Debt MAT Issue Fails: ITAT Mumbai

DCIT Vs Bank of Baroda (ITAT Mumbai) Reopening U/s 147 Quashed – Audit Objection Not Tangible Material After 4 Years – Bad Debt MAT Issue Fails – ITAT Mumbai The Revenue challenged CIT(A)’s order quashing reassessment initiated u/s 147 relating to MAT computation and bad debts written off of ₹907 Cr. The reopening was issued after four years mainly based on a revenue audit objection alleging wrong allowance while computing book profit u/s 115JB. ITAT held that reassessment beyond four years is permissible only if there is failure by the assessee to disclose fully & tr...