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Erroneous bank information concerning a term deposit could not support reassessment for assessment year 2015-16 when it was the sole basis for the notice and the normal three-year period had expired. Extended-period reassessment required satisfaction of the statutory conditions, which technical or system-generated erroneous data could not meet. The notice seeking an explanation, together with the consequential reassessment, assessment and penalty orders, was set aside. The writ petition succeeded, and costs were directed against the Bank for providing the incorrect information.
Erroneous bank information concerning a term deposit could not support reassessment for assessment year 2015-16 when it was the sole basis for the notice and the normal three-year period had expired. Extended-period reassessment required satisfaction of the statutory conditions, which technical or system-generated erroneous data could not meet. The notice seeking an explanation, together with the consequential reassessment, assessment and penalty orders, was set aside. The writ petition succeeded, and costs were directed against the Bank for providing the incorrect information.
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