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    <title>2023 (3) TMI 852 - ITAT KOLKATA</title>
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    <description>Reassessment under section 148 was stated to be valid where it was based on specific information and recorded reasons, rather than a mere change of opinion. In the context of amalgamation of five rural banks under a Central Government notification, section 72AA was applied to permit carry forward and set off of the merged banks&#039; accumulated losses. The note also states that ad hoc disallowances for provision for fraud, gratuity, contingencies and dacoity were deleted for lack of adequate basis, while the disallowance relating to penalty was sustained because its allowable character was not established.</description>
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