1996 (5) TMI 3

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....n the affirmative that is in favour of the Revenue and against the assessee : " Whether, on the facts and in the circumstances of the case, the assessments for the years 1960-61, 1961-62 and 1962-63 have been validly reopened under section 147(b) of the Income-tax Act, 1961 ? " The appellant is the Andhra Bank Limited and the assessment years concerned are 1960-61 to 1962-63. The bank was fo....

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....f income stating that by following the aforesaid method, the bank was experiencing several difficulties in the matter of accounting and therefore it is changing the method of accounting with effect from the accounting year relevant to the assessment year 1959-60. According to this changed method of accounting, it appears, the bank ignored the accrued amounts of interest paid or received relating t....

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....nt years 1960-61 to 1962-63 under clause (b) of section 147 of the Income-tax Act, 1961, and it is this controversy we are concerned with in these appeals. Against the reassessments made for the said three assessment years, the bank appealed to the Appellate Assistant Commissioner, but without success. On further appeal preferred by the assessee, there was a difference of opinion between the two m....

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.... not a case of an inadvertent mistake which was discovered later on after completion of the assessment or oversight. Once it is found that the change in the method of accounting was knowingly allowed by the Income-tax Officer after taking into account all the relevant facts it is not permissible for the Income-tax Officer, or his successor, to reopen the assessment at a later point of time under s....