349 ITR

Section 147, Sec. 36(1)(Viii)

Bombay H.C : The notice for reopening of assessment issued u/s.148 of the Income Tax Act was bad in law as the notice was based on mere change of opinion even though the assessment was reopened within a period of four years and the record shows that the Assessee Company had claimed excess deduction u/s. 36(1)(viii) of the Income Tax Act on income which included non fund base income and income from short term finance

High Court Of Bombay CIT-3, Mumbai VS. ICICI Bank Ltd. Assessment Year : 1996-97 Section : 147, 36(1)(Viii) S.J. Vazifdar

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