DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BENGALURU, BENGALURU vs. CANARA BANK, BENGALURU

ITA 297/BANG/2024Status: DisposedITAT Bangalore17 January 2025AY 2018-19Bench: SHRI WASEEM AHMED (Accountant Member), SHRI KESHAV DUBEY (Judicial Member)40 pages
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What did the Tribunal hold?

The Tribunal held that for calculating average aggregate advances of rural branches under Section 36(1)(viia), both outstanding and fresh advances should be considered. The issue regarding the population of branches for rural status was remitted to the CIT(A) for verification.

What were the facts?

Canara Bank filed its return of income for AY 2017-18 and 2018-19. The Assessing Officer made additions and disallowances, and computed book profit under Section 115JB. The CIT(A) partly allowed the assessee's appeal.

What were the issues?

The applicability of Section 14A for disallowance of expenditure related to exempt income and the method for calculating average aggregate advances for rural branches under Section 36(1)(viia).

Which sections of the Income-tax Act were involved?

Section 14A,Section 115JB,Section 36(1)(viia)

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Income Tax Appellate Tribunal, “C’’BENCH: BANGALORE

Before: SHRI WASEEM AHMED & SHRI KESHAV DUBEY

For Respondent: Ms. Neera Malhotra, D.R
Hearing: 22.10.2024Pronounced: 17.01.2025

PER KESHAV DUBEY, JUDICIAL MEMBER:

These are cross appeals filed by

The order continues below.

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