PUNJAB NATIONAL BANK,DELHI vs. DCIT, CIRCLE-19(1), DELHI

ITA 2712/DEL/2024Status: DisposedITAT Delhi17 November 2025AY 2020-21Bench: SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER, SHRI NAVEEN CHANDRA (Accountant Member)12 pages
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What did the Tribunal hold?

The Tribunal restored the issue of carry forward of business losses to the AO for verification, allowing it for statistical purposes. The issues of bad debts and Section 115JB were also set aside to the AO for adjudication. The Revenue's grounds regarding Section 14A, Rule 37BA(2), and carried forward long-term capital loss were decided against the Revenue.

What were the facts?

The appeals by the assessee and Revenue were against the order of NFAC for AY 2020-21. The assessee's primary grievance was the disallowance of set-off of carry forward business losses. The assessee also raised additional grounds concerning bad debts and applicability of Section 115JB.

What were the issues?

Whether carry forward business losses, bad debts, and the applicability of Section 115JB were correctly handled. Also, the validity of disallowance under Section 14A and the treatment of TDS credit were examined.

Which sections of the Income-tax Act were involved?

Section 36(1)(vii),Section 36(1)(viia),Section 115JB,Section 14A,Section 37BA(2),Section 143(3),Section 194A

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Income Tax Appellate Tribunal, DELHI ‘A’ BENCH,

Before: SHRI SATBEER SINGH GODARA, & SHRI NAVEEN CHANDRA

For Appellant: Shri K. Sampath, Adv, Shri V. Rajakumar, Adv
For Respondent: Shri Jitender Singh, CIT-DR
Hearing: 28.08.2025Pronounced: 28.08.2025

Heard together (2 matters)

ITA No. 2712/DEL/2024
ITA No. 3039/DEL/2024

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

PER NAVEEN CHANDRA, AM :-

ITA No. 2712 & 3039 /DEL/2024 Punjab National Bank [A.Y 2020-21]

Both the above captioned cross appeals by the assessee and the Revenue are directed against the order of the NFAC, New Delhi dated

28.03.

2024 pertaining to A.Y 2020-21 respectively.

2.

Since common grievance is involved in the captioned appeals and pertain to same assessee, they were heard together and are disposed of by this common order for the sake of convenience and brevity.

ITA No. 2712/DE

The order continues below.

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