THE SOUTH INDIAN BANK LIMITED,THRISSUR vs. ACIT, CIRCLE 1(1)& TPS, THRISSUR

ITA 286/COCH/2024Status: DisposedITAT Cochin23 October 2024AY 2014-2015Bench: Shri Satbeer Singh Godara (Judicial Member), Shri Amarjit Singh (Accountant Member)12 pages
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What did the Tribunal hold?

The Tribunal restored issues related to Section 234D and 244A interest to the Assessing Officer for fresh adjudication in AY 2004-05. For AY 2006-07, Section 244A interest was allowed. For AY 2008-09, a claim for deduction under Section 35D was restored to the AO. For AY 2013-14 and 2014-15, the deduction under Section 36(1)(viii) was allowed. For AY 2019-20, the disallowance of penalty paid to the RBI was deleted.

What were the facts?

The assessee, South Indian Bank Ltd., filed six appeals before the ITAT challenging various disallowances and interest computations made by the lower authorities. The appeals covered assessment years from 2004-05 to 2019-20.

What were the issues?

The appeals involved disputes regarding the computation of interest under various sections, the allowability of expenses as revenue expenditure versus capital expenditure, and the deductibility of penalties paid to regulatory authorities.

Which sections of the Income-tax Act were involved?

Section 234D,Section 244A,Section 220(2),Section 154,Section 35D,Section 36(1)(viii),Section 37(1)

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Cases cited in this judgment(5)Show list

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Income Tax Appellate Tribunal, COCHIN BENCH, COCHIN

Before: Shri Satbeer Singh Godara & Shri Amarjit Singh

For Appellant: Shri Naresh S., CA
For Respondent: Dr. S. Pandian, CIT-DR
Hearing: 22.08.2024Pronounced: 23.10.2024

Heard together (6 matters)

ITA No. 232/Coch/2024
ITA No. 233/Coch/2024
ITA No. 283/Coch/2024
ITA No. 285/Coch/2024
ITA No. 286/Coch/2024
ITA No. 288/Coch/2024

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Per Bench

These assessee’s six appeals arise against orders of the CIT(A)-2, Chandigarh in proceedings u/s. 250 of the Income Tax Act, 1961 (the Act) as under : -

Sr. ITA No. AY DIN & Order No. Date No. 1 232/Coch/2024 2004-05 ITBA/NFAC/S/250/2023- 25.01.2024 24/1060144092(1) 2 233/Coch/2024 2006-07 ITBA/NFAC/S/250/2023- 29.01.2024 24/1060196214(1) 3 283/Coch/2024 2008-09 ITBA/NFAC/S/250/2023- 07.02.2024 24/10606133339(1) The South Indian Bank Ltd. 4 285/Coch/2024 2013-14 ITBA/NFAC/S/250/2023- 07.02.2024 24/1060597167(1) 5 2

The order continues below.

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