2019 (9) TMI 314

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.... circumstance of the case and in law, the Tribunal was justified in quashing the reassessment proceeding, initiated by the AO u/s. 147 r.w.s. 148 of the IT Act, 1961? (b) Whether on the facts and in the circumstance of the case and in law, the Tribunal was justified in quashing the reopening u/s. 147 of the Act holding that the reasons had not mentioned that the failure of the assesssee to disclose fully and truly the material facts has led to escapement of income without appreciating that mere submission of details during the original proceeding do not tantamount to submission of all material facts truly and fully? (c) Whether on the facts and in the circumstance of the case and in law, the Tribunal was justified in quash....

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....out charging in same the profit and loss account is not writing off at all. So, the bad debt of Rs. 11,46,19,000/- which is not debited in the profit and loss account is required to be disallowed. 2. In response, Shri Saurabh Kuwadia, Sr. Manager - Taxation, from the assessee company attended and submitted the details called for from time to time. The assessee vide its reply submitted on 31.10.2012 stated as under:- (a) Total provision made for doubtful debs/ loans and advances is Rs. 2,87,77,700/- (page 16 of the signed accounts). In revised computation of income, whole amount of Rs. 2,87,77,000/- has been disallowed. (b) Amount claimed in the revised computation of income is Rs. 11,46,19,000/- as bad debts writt....