M/S S B B J,JAIPUR vs. ACIT, JAIPUR
What did the Tribunal hold?
The Tribunal held that the disallowance under Section 14A computed as per Rule 8D was not justified as Rule 8D was operational from AY 2008-09. It also held that the disallowance of prior period expenses was partly confirmed and partly deleted. The disallowance made by the AO regarding deduction u/s 36(1)(viia) was not maintainable and directed to be deleted.
What were the facts?
The assessee, State Bank of Bikaner & Jaipur, appealed against the disallowance of proportionate interest and administrative expenditure under Section 14A, and disallowance of prior period expenses. The Revenue also filed appeals against certain aspects of the order.
What were the issues?
Applicability of Rule 8D for disallowance under Section 14A and allowability of prior period expenses and deduction under Section 36(1)(viia).
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Cases cited in this judgment(7)Show listHide 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.
- CIT v. Kelvinator of India Ltd.1,673 citing187 Taxmann 312 · 2010 · SC · Read judgment
- T.S. Balaram ITO v. Volkart Bros.382 citing82 ITR 50 · 1971 · SC
- CIT v. Foramer France253 citing264 ITR 567 · 2003 · SC
- Padmasundara Rao v. State of Tamil Nadu123 citing255 ITR 147 · 2002 · SC
- American Express International Banking Corporation v. CIT90 citing258 ITR 601 · 2002 · HC
- CIT v. Bank of Rajasthan Ltd.51 citing316 ITR 391 · 2009 · HC
- CIT v. Foramer France23 citing247 ITR 463 · 2010 · HC
Income Tax Appellate Tribunal, JAIPUR BENCHES, JAIPUR
Before: SHRI KUL BHARAT, JM & SHRI VIKRAM SINGH YADAV, AM vk;dj vihy la-@ITA No. 921/JP/2009 & 299/JP/2014
Heard together (2 matters)
Read from the judgment's own cause title. This page is filed under one of them.
PER BENCH Out of bunch of 21 appeals, these four cross appeals pertaining to the A.Y. 2007-08 are filed by the Assessee and Revenue i.e. 921/JP/2009, 41/JP/2010, 299/JP/2014 & 28/JP
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