2016 (11) TMI 805

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..... notice under section 148 of the Income-tax Act, 1961 has specifically recorded that there was no material available on record to indicate that the bad debts have been written off as mandatorily required under section 36(1)(vii) of the Income-tax Act, 1961 as amended with effect from April 1, 1989. If that be so, we find no fault with the notice issued. Consequently, we allow this appeal by settin .....

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..... eave granted. 3. The Revenue challenges the order of the High Court dated February 22, 2011 passed in Writ Petition (LOD) No. 140 of 2011 by which the reopening of the assessment of the respondent-assessee (Sumitomo Mitsui Banking Corporation) sought to be made by issuing a notice under section 148 of the Income-tax Act, 1961 has been interfered with. 4. We have gone through the order passed .....

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..... on filed by the respondent-assessee challenging the said notice. 6. We, however, make it clear that we have expressed no opinion on the merits of the reassessment, which has been made on December 24, 2010, and it will be open for the respondent-assessee to urge all questions as may be open, in law, in the event the assessee seeks to challenge the reassessment order dated December 24, 2010. - .....

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