THE DY CIT CIR 1(1), MUMBAI vs. M/S. HOUSING DEVELOPMENT FINANCE CORPN LTD, MUMBAI

ITA 337/MUM/2005Status: DisposedITAT Mumbai05 July 2024AY 2000-200145 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal decided that income from housing finance for residential purposes for less than 5 years and income from temporary deployment of funds in treasury operations are eligible for deduction under Section 36(1)(viii). However, income from housing finance for non-residential purposes is not eligible. The Tribunal directed the Assessing Officer to re-compute the eligible profit.

What were the facts?

The assessee, HDFC Bank (successor to Housing Development Finance Corporation Ltd.), is a housing finance institution. The appeals concern assessment years 1999-2000 to 2001-02, involving issues related to disallowance of provision for exchange loss, computation of deduction under Section 36(1)(viii), and exemption of dividend and bond interest income.

What were the issues?

The key issues were whether provisions for exchange loss were allowable and how to compute profits eligible for deduction under Section 36(1)(viii), considering various types of income and expense allocations.

Which sections of the Income-tax Act were involved?

Section 36(1)(viii),Section 10(33),Section 10(23G),Section 45

AI-generated summary — verify with the full judgment below

Cases cited in this judgment(2)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, “D” BENCH MUMBAI

Before: SHRI GIRISH AGRAWAL & SHRI SUNIL KUMAR SINGH

Pronounced: 05.07.2024

Heard together (2 matters)

ITA No.7447/MUM/2004
ITA No.7532/MUM/2004

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

ITA Nos.7532/MUM/2004 & others HDFC Bank Ltd. AYs 1999-2000, 2000-01 & 2001-02 PER GIRISH AGRAWAL, ACCOUNTANT MEMBER:

All these six appeals by the assessee and Rev

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 36(1)(viii)

All 364 judgments and leading authorities on Section 36(1)(viii) →

Recent GST High Court judgments

Search GST case law →