Section 115JB of Income Tax Act: Applicability to Banks Under Scrutiny; Impact of Banking Regulation Act Not Considered.

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....Applicability of provisions of section 115JB of the Act to the assessee bank - 'Banking Company' or 'Corresponding new bank '- corresponding new bank - We noticed earlier that the Ld CIT(A) has proceeded to decide this issue by observing that all provisions of BR Act are applicable to the Company. We notice that the Ld CIT(A) did not consider the effect of provisions of sec. 51 of the BR Act upon the assessee. - AT....