2002 (11) TMI 29 - KERALA HIGH COURT

Whether the Government securities held by the appellants as required under the provisions of the Banking Regulation Act, 1949, are stock-in-trade of the assessee-banks and, consequently, the assessee-banks are entitled to revalue the said securities at the close of the assessment year and claim depreciation in respect of the notional loss suffered by the assessee-banks in respect of the said securities in the assessment under the Act. - Tribunal has rightly held that the securities held by the assessee-bank in all these cases are the stock-in-trade of the business of the assessee-banks and the notional loss suffered on account of the revaluation of the said securities at the close of the year is an allowable deduction in the computation of the profits of the appellant - Further, the reopening of the assessment by issuing notice under section 147 of the Act beyond a period of four years is legal and valid