In Brief
The Supreme Court upheld the validity of a reopening notice issued to Sumitomo Mitsui Banking Corporation under Section 148 of the Income Tax Act, 1961. Although the assessee claimed to have transferred bad debts to another bank for realization, the income tax authority had explicitly recorded that no material on record showed the debts were mandatorily written off as required by Section 36(1)(vii). The Court found the notice valid and set aside the High Court's interference, while reserving the assessee's rights to challenge the reassessment order's merits.
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