ACIT, CIRCLE-2(1)(1), MUMBAI vs. M/S BANK OF INDIA, MUMBAI

ITA 1547/MUM/2023Status: DisposedITAT Mumbai30 January 2026AY 2016-2017Bench: IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER SHRI SANDEEP SINGH KARHAIL (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the penalty levied on the Singapore Branch for violating anti-money laundering regulations was for an offence prohibited by law and not compensatory. Therefore, it could not be allowed as a deduction. The appeals were decided based on various grounds raised by both the assessee and the revenue.

What were the facts?

The assessee, Bank of India, filed cross-appeals against the CIT(A)'s order concerning disallowances under Section 14A and other grounds. A significant issue involved a penalty of Rs. 21.64 crore levied on the assessee's Singapore Branch for violations related to anti-money laundering regulations.

What were the issues?

Whether a penalty for violation of anti-money laundering regulations is a deductible business expense. The appeals also involved issues related to disallowance under Section 14A, amortization of lease premium, exclusion of foreign branch profits, and computation of book profit under Section 115JB.

Which sections of the Income-tax Act were involved?

Section 14A,Section 32,Section 90,Section 91,Section 115JB,Section 37(1)

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Income Tax Appellate Tribunal, “I” BENCH, MUMBAI

Before: SHRI VIKRAM SINGH YADAVSHRI SANDEEP SINGH KARHAIL

For Appellant: Shri C. Naresh
For Respondent: Shri Satya Pal Kumar, CIT (DR)

Heard together (2 matters)

ITA No.1452/MUM/2023
ITA No.1548/MUM/2023

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

PER BENCH :

The present cross-appeals have been filed by the assessee and the Revenue challenging the separate impugned

The order continues below.

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