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Sec 147 Reopening After 4 Years Invalid; Audit Objection Not Tangible; Bad Debt MAT Issue Fails: ITAT Mumbai
Case Law Details
- Case Name
- DCIT Vs Bank of Baroda (ITAT Mumbai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2015-16
- Courts
- All ITAT, ITAT Mumbai
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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...
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