UNION BANK OF INDIA,MUMBAI vs. DCIT, CIR-(LTU)-2, MUMBAI

ITA 1437/MUM/2023Status: DisposedITAT Mumbai25 July 2023AY 2009-1019 pages
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What did the Tribunal hold?

The Tribunal held that the issue of deduction under Section 36(1)(viia) for provisions on standard assets and restructured debts needed to be decided afresh by the Assessing Officer. Regarding interest calculation, the Tribunal ruled that any fraction of a month should be treated as a full month as per Rule 119A(b), not ignored as per Rule 119A(a).

What were the facts?

The assessee, Union Bank of India, appealed against the CIT(A)'s orders concerning deductions for bad debts and the calculation of interest on refunds. The primary dispute revolved around the eligibility of provisions for standard assets and restructured debts for deduction under Section 36(1)(viia) and the method of calculating interest under Section 244A.

What were the issues?

Whether provisions for standard assets and restructured debts are eligible for deduction under Section 36(1)(viia), and the correct method for calculating interest on refunds under Section 244A.

Which sections of the Income-tax Act were involved?

Section 36(1)(viia),Section 244A

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Cases cited in this judgment(3)Show list

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Income Tax Appellate Tribunal, MUMBAI BENCH “F” MUMBAI

Before: SHRI OM PRAKASH KANT & MS. KAVITHA RAJAGOPAL&

For Respondent: Shri Ankush Kapoor, DR
Hearing: 10/07/2023Pronounced: 25/07/2023

PER OM PRAKASH KANT, AM

These three appeals by the assessee, two for assessment year (AY) 2009-10 and one for AY 2013-14, are directed against the three separate orders, all dated 20.03.2023, passed by the Ld. Commissioner of Income-tax (Appeals) – National Faceless Appeal

ITA No. 1437, 1438 & 1439/M/2023 M/s Union Bank of India

Centre, Delhi [in short ‘the Ld. CIT(A)’]. The appeals for assessment year 2009-10 are arising from two different orders of Assessing Officer giving effect to the order of the ld CIT(A) and Income Tax appellate Tribunal (ITAT) respectively. As common grounds have been

The order continues below.

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