Bank taxation principles: opening FCTR cannot be taxed, section 115JB inapplicable, and reassessment on stale material fails

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....In bank tax assessments, the opening Foreign Currency Translation Reserve balance could not be taxed under ICDS-VI because the Act taxes only current-year income and a CBDT circular cannot override sections 4 and 5. Section 115JB was held inapplicable to corresponding new banks, section 14A could not be applied to securities held as stock-in-trade, and reassessment based only on existing records failed for want of fresh tangible material.....