#Proviso

The Calcutta High Court ruled that the first proviso to Section 36(1)(viia)(a) of the Income tax Act 1961 grants banks an option to claim additional provision for doubtful or loss assets, allowing cumulative deduction within statutory limits. This clarifies that the proviso is not an alternative to the main clause, benefitting banking assessees seeking higher tax deductions.

ITAT Pune quashes reassessment notice u/s 148 for AY 2015-16 after harmonious construction of Section 149(1) provisos. The ruling underscores strict compliance with limitation periods in reassessment proceedings, impacting taxpayers facing similar notices.