STATE BANK OF INDIA (SUCCESSOR TO STATE BANK OF BIKANER & JAIPUR),MUMBAI vs. ACIT -CIRCLE 2(2)(1), MUMBAI

ITA 2873/MUM/2019Status: DisposedITAT Mumbai29 September 2022AY 2015-1638 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that interest on NPA/NPI accounts should be taxed as per RBI guidelines, not strictly on accrual basis. It also ruled that investments held as stock-in-trade by the bank, and losses on revaluation thereof, are allowable as deduction. The issue of broken period interest was also decided in favour of the assessee.

What were the facts?

The assessee, a public sector bank, filed its return of income. The Assessing Officer made several additions and disallowances, including on account of unrealized interest on NPAs, recovery of bad debts, disallowance under Section 14A, and interest on IPDI bonds. The CIT(A) partly allowed the assessee's appeal.

What were the issues?

The key issues were the taxability of unrealized interest on NPAs, the treatment of recovery of bad debts, disallowance of expenses under Section 14A for stock-in-trade investments, and the nature of broken period interest.

Which sections of the Income-tax Act were involved?

Section 14A,Section 43D

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(22)Show list

Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.

Income Tax Appellate Tribunal, “G” BENCH, MUMBAI

Before: SHRI OM PRAKASH KANT (ACCOUNT MEMBER) & MS. KAVITHA RAJAGOPAL

For Appellant: Shri Jeet kamadar &
For Respondent: Shri Kailash Kanojia
Hearing: 24.08.2022Pronounced: 29.09.2022

Heard together (2 matters)

I.T.A. No. 3033/Mum/2019
I.T.A. No. 2873/Mum/2019

Read from the judgment's own cause title. This page is filed under one of them.

Per: Om Prakash Kant (AM)

2 State Bank of India ITA No. 3033/2873/Mum/2019

These cross appeals by the assessee and Revenue are directed against order dated 30/01/2018 passed by the Ld. CIT(Appeals)-5, Mumbai [in short the Ld. CIT(A)] for A.Y.201

The order continues below.

Read the full judgment

A free account opens 10 full judgments a month. Re-reading one you have already opened does not count again.

Create a free accountSign in

See plans and prices

The summary, the parties, the sections and the citations above are open to everyone and always will be. Only the text of the order and the PDF are metered.

More judgments on Section 14A

All 15,875 judgments and leading authorities on Section 14A →

Recent GST High Court judgments

Search GST case law →