DCIT, CIRCLE - 19(1), DELHI vs. PUNJAB NATIONAL BANK (EARLIER KNOWN AS ORIENTAL BANK OF COMMERCE), DELHI

ITA 3161/DEL/2024Status: DisposedITAT Delhi24 October 2025AY 2017-1818 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal upheld the CIT(A)'s decision to delete the disallowances. It found that the assessee had provided sufficient evidence for interest payments and that Section 14A did not apply to investments held as stock-in-trade. The Tribunal also noted that many of these issues were recurring and had been decided in favor of the assessee in previous years.

What were the facts?

The Revenue appealed against the CIT(A)'s deletion of various disallowances made by the Assessing Officer. These disallowances pertained to interest payments, Section 14A expenses, depreciation on temporary erections, inter-office adjustments, software expenses, depreciation on investments, provision for depreciation on Government Securities, amortization on HTM securities, and provision for Non-Performing Investments.

What were the issues?

Whether the CIT(A) erred in deleting disallowances related to interest payments, Section 14A expenses, depreciation, and provisions for various investments and securities, considering the evidence and prior rulings.

Which sections of the Income-tax Act were involved?

Section 143(3),Section 14A,Section 36(1)(viia),Section 36(2)(v)

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Income Tax Appellate Tribunal, DELHI BENCH: ‘C’ NEW DELHI

Before: SHRI SATBEER SINGH GODARA & SHRI AVDHESH KUMAR MISHRA

Hearing: 28.07.2025Pronounced: 24.10.2025

PER SATBEER SINGH GODARA, JM This Revenue’s appeal for assessment year 2017-18, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the “CIT(A)/NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2022-23/1049284753(1), dated 31.01.2023 involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’). Heard both the parties. Case file perused.

2.

Delay of 458 days in filing of the Revenue’s instant appeal is condoned in larger interest of justice and in light of Collector, Land & Acquisition vs. Mst. Katiji & Others (1987) 167 ITR 471 (SC).

3.

The Revenue pleads the following

The order continues below.

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