https://www.taxtmi.com/caselaws?id=435466 Reassessment initiated after processing under section 143(1) was treated as valid where recorded reasons relied on specific information concerning bank amalgamations and loss set-off claims, constituting tangible material rather than a change of opinion. Accumulated losses of five amalgamated rural banks were allowable for carry forward and set-off under section 72AA because the amalgamation occurred under a Central Government banking scheme. Ad hoc disallowances for fraud, contingencies, gratuity and dacoity provisions lacked adequate support or concerned allowable business liabilities, whereas penalty expenditure remained disallowable because its nature and eligibility under section 37 were not established. en-us Wed, 15 Mar 2023 00:00:00 +0530 Fri, 20 Dec 2024 10:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=435466 Reassessment initiated after processing under section 143(1) was treated as valid where recorded reasons relied on specific information concerning bank amalgamations and loss set-off claims, constituting tangible material rather than a change of opinion. Accumulated losses of five amalgamated rural banks were allowable for carry forward and set-off under section 72AA because the amalgamation occurred under a Central Government banking scheme. Ad hoc disallowances for fraud, contingencies, gratuity and dacoity provisions lacked adequate support or concerned allowable business liabilities, whereas penalty expenditure remained disallowable because its nature and eligibility under section 37 were not established. Case-Laws Income Tax Wed, 15 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=435466