2018 (11) TMI 1560

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....Appeal under Section 260A of the Income Tax Act, 1961 (the Act) challenges the order dated 25th March, 2015 passed by the Income Tax Appellate Tribunal (the Tribunal). This appeal relates to Assessment Year 2001-02. 2. The Revenue has urged only the following re-framed question of law for our consideration : (i) Whether on the facts and circumstances of the case and in law, the Tribunal was ....

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.... income such interest is not offered to tax and only the interest which has become due and receivable during the year is offered to tax. From the A.Ys. 200304 onwards, such interest, "Accrued but not due at the end of the year" was taxed by the Assessing Officer. Such additions have been confirmed and upheld by the CIT(A) in assessee bank's first appeal subject to the direction that the credit....

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....h is to be added back and is taken as the income of the year and the same is required to be taxed accordingly. As a result of which income chargeable to tax has escaped assessment. 5. In view of the above, I have to reason to believe that income chargeable to tax has escaped assessment and the case is fit for issue of notice under Section 148 of the I.T. Act." 5. The impugned order of the Tr....

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....d a period of four years from the end of the relevant assessment year i.e. 2001-02 in respect of regular assessment completed under Section 143(3) of the Act. The jurisdictional requirement to issue a reopening notice under the proviso to Section 147 of the Act, is a failure on the part of the assessee to truly and fully disclose all material facts necessary for assessment during the scrutiny proc....