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

ITA 938/BANG/2024Status: DisposedITAT Bangalore16 October 2024AY 2014-1520 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal noted that the issue of Section 14A disallowance was settled by the jurisdictional High Court in the assessee's own case, which held that expenditure must be 'incurred' to attract Section 14A. The judgment also discussed the applicability of Section 115JB concerning banking companies and the Companies Act.

What were the facts?

The assessee, Canara Bank (erstwhile Syndicate Bank), appealed against the CIT(A)'s order upholding disallowance under Section 14A and the applicability of Section 115JB. The ITAT had previously set aside these issues to the CIT(A) for fresh adjudication.

What were the issues?

Whether expenditure was incurred for earning exempt income to attract disallowance under Section 14A, and the applicability of Section 115JB for banking companies.

Which sections of the Income-tax Act were involved?

Section 14A,Section 115JB

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Income Tax Appellate Tribunal, C BENCH: BANGALORE

Before: SHRI WASEEM AHMED & SHRI KESHAV DUBEY

For Appellant: Ms. Brinda Rameswaran, A.R, Ms. Neera Malhotra, D.R
For Respondent: Ms. Brinda Rameswaran, A.R, Ms. Neera Malhotra, D.R
Pronounced: 05.09.2024

PER KESHAV DUBEY, JUDICIAL MEMBER:

These appeals filed by the assessee are against the orders both dated 21.3.2024 passed by the ld. CIT(A)/NFAC u/s 250 r.w.s. 254 of the Income Tax Act, 1961 (in short "The Act") for the AYs 2013-14 & 2014-15. Since the issues in both the appeals are common, these are clubbed together, heard together and disposed of by this common order for the sake of convenience. The grounds raised by the assessee for the Asst. year 2013-14 in ITA No.937/Bang/2024 are taken as base for deciding both the appeals. The Grounds raised are as follows:

1.

"The order of

The order continues below.

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