YES BANK LIMITED,MUMBAI vs. ADDITIONAL COMMISSIONER OF INCOME TAX (APPEALS), PANCHKULA
In the result, the appeal of the assessee bearing ITA No
ITA 1093/MUM/2025[2020-21]Status: DisposedITAT Mumbai21 Apr 2025AY 2020-21
Bench: Shrinarendra Kumar Billaiya & Shri Anikesh Banerjeeyes Bank Limited Vs Additional Commissioner Of Income Yes Bank House, 8Th Floor, Tax (Appeals), Panchkula Prabhat Colony, Off Western Express Highway, Santacruz East, Mumbai-400 055 Pan : Aaacy2068D Appellant Respondent Additional Commissioner Of Vs Yes Bank Limited Yes Bank House, 8Th Floor Income Tax (Appeals), Panchkula Prabhat Colony, Off Western Express Highway, Santacruz East, Mumbai-400 055 Pan : Aaacy2068D Appellant Respondent
For Appellant: Shri Yogesh Thard &Ms.Vidhi SalotFor Respondent: Ms. Ramapriya Raghavan - CIT DR&
Section 139(1)Section 143(1)Section 234ASection 234CSection 250Section 36(1)(va)Section 43B
…erein it was held that where two views were possible at the time of the original assessment, a subsequent retrospective amendment would not justify invoking revisionary powers under Section 263. Further reliance was placed on Rallis India Ltd. v. ACIT, (2010) 323 ITR 54 (Bom), where the Hon’ble Bombay High Court held that reassessment was unsustainable if based merely on a change of opinion in the absence of tangible material. 5. On merits, the Ld. AR submitted that the assessee, Yes Bank Ltd., was placed under a moratorium by the Reserve Bank of India from 05.03.2020 to 18.03.2020, under the directions of the G…