ANZ Grindlays Bank PLC v. CIT

241 ITR 269Reported decision2000#9574 most cited

What is ANZ Grindlays Bank PLC v. CIT authority for?

An order charging interest under Section 220(2) of the Income-tax Act, 1961 is not appealable as it is neither part of the assessment order nor specifically provided for under Section 246 of the Act. However, there are conflicting decisions on this issue, and some benches have considered such appeals on merits.

11

judgments rely on this decision, according to BharatTax’s citation analysis of 366,315 Indian tax judgments — from 2019 to 2025.

Also referred to as

ANZ Grindlays Bank PLC v. CIT · section 220(2) · interest u/s 220(2) · appealable order · assessment order · section 246 · income tax appeal · charging interest · waiver of interest · CIT(Appeals) · conflicting decisions

Also reported as

108 Taxmann 328

Sections most often in play

Section 143(3)Section 144C(13)Section 154Section 220(2)Section 246(1)Section 246ASection 250Section 251

Issues it is cited on

section 202section 158bcsection 220section 220(2)section 246section 22section 246aregular assessmentsection 24section 154section 15section 25

Judgments citing ANZ Grindlays Bank PLC v. CIT

Visa Worldwide Pte. Limited, Singapore vs. Deputy Commissioner of Income-Tax (International Taxation), Bengaluru -2(2), Bengaluru

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 394/BANG/2025[2019-20]Status: DisposedITAT Bangalore07 Jul 2025AY 2019-20

Bench: Shri Laxmi Prasad Sahu & Shri Prakash Chand Yadav

For Appellant: Smt. Tanmayee Rajkumar, A.RFor Respondent: Sri Aarshi Prasad, D.R
Section 143(3)Section 154Section 220(2)Section 222(2)Section 246(1)Section 246ASection 250

…h Section 250 and 251 of the Act. Be that as it may, it definitely falls within the appealable orders under Section 246(1) of the Act. No doubt, CIT(Appeals) has relied on the decision of Calcutta High Court in the case of ANZ Grindlays Bank PLC v. CIT [2000] 241 ITR 269/108 Taxman 328, which held that an order charging interest under section 220(2) was not appealable. Nevertheless, in the case of CIT v. Chika Overseas (P.) Ltd. [2012] 209 Taxman 456/23 taxmann.com 315, Bombay High Court had considered a tax-appeal assailing levy of interest under Section 220(2) of the Act. Since there are conflicting decisions o…

Visa Worldwide Pte. Limited, Singapore vs. Deputy Commissioner of Income-Tax (International Taxation), Bengaluru -2(2), Bengaluru

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 393/BANG/2025[2018-19]Status: DisposedITAT Bangalore07 Jul 2025AY 2018-19

Bench: Shri Laxmi Prasad Sahu & Shri Prakash Chand Yadav

For Appellant: Smt. Tanmayee Rajkumar, A.RFor Respondent: Sri Aarshi Prasad, D.R
Section 143(3)Section 154Section 220(2)Section 222(2)Section 246(1)Section 246ASection 250

…h Section 250 and 251 of the Act. Be that as it may, it definitely falls within the appealable orders under Section 246(1) of the Act. No doubt, CIT(Appeals) has relied on the decision of Calcutta High Court in the case of ANZ Grindlays Bank PLC v. CIT [2000] 241 ITR 269/108 Taxman 328, which held that an order charging interest under section 220(2) was not appealable. Nevertheless, in the case of CIT v. Chika Overseas (P.) Ltd. [2012] 209 Taxman 456/23 taxmann.com 315, Bombay High Court had considered a tax-appeal assailing levy of interest under Section 220(2) of the Act. Since there are conflicting decisions o…

Visa Worldwide Pte. Limited, Singapore vs. Deputy Commissioner of Income-Tax (International Taxation), Bengaluru -2(2), Bengaluru

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 392/BANG/2025[2017-18]Status: DisposedITAT Bangalore07 Jul 2025AY 2017-18

Bench: Shri Laxmi Prasad Sahu & Shri Prakash Chand Yadav

For Appellant: Smt. Tanmayee Rajkumar, A.RFor Respondent: Sri Aarshi Prasad, D.R
Section 143(3)Section 154Section 220(2)Section 222(2)Section 246(1)Section 246ASection 250

…h Section 250 and 251 of the Act. Be that as it may, it definitely falls within the appealable orders under Section 246(1) of the Act. No doubt, CIT(Appeals) has relied on the decision of Calcutta High Court in the case of ANZ Grindlays Bank PLC v. CIT [2000] 241 ITR 269/108 Taxman 328, which held that an order charging interest under section 220(2) was not appealable. Nevertheless, in the case of CIT v. Chika Overseas (P.) Ltd. [2012] 209 Taxman 456/23 taxmann.com 315, Bombay High Court had considered a tax-appeal assailing levy of interest under Section 220(2) of the Act. Since there are conflicting decisions o…

Visa Worldwide Pte. Limited, Singapore vs. Deputy Commissioner of Income-Tax (International Taxation), Bengaluru -2(2), Bengaluru

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 391/BANG/2025[2016-17]Status: DisposedITAT Bangalore07 Jul 2025AY 2016-17

Bench: Shri Laxmi Prasad Sahu & Shri Prakash Chand Yadav

For Appellant: Smt. Tanmayee Rajkumar, A.RFor Respondent: Sri Aarshi Prasad, D.R
Section 143(3)Section 154Section 220(2)Section 222(2)Section 246(1)Section 246ASection 250

…h Section 250 and 251 of the Act. Be that as it may, it definitely falls within the appealable orders under Section 246(1) of the Act. No doubt, CIT(Appeals) has relied on the decision of Calcutta High Court in the case of ANZ Grindlays Bank PLC v. CIT [2000] 241 ITR 269/108 Taxman 328, which held that an order charging interest under section 220(2) was not appealable. Nevertheless, in the case of CIT v. Chika Overseas (P.) Ltd. [2012] 209 Taxman 456/23 taxmann.com 315, Bombay High Court had considered a tax-appeal assailing levy of interest under Section 220(2) of the Act. Since there are conflicting decisions o…

Visa Worldwide Pte. Limited, Singapore vs. Deputy Commissioner of Income-Tax (International Taxation), Bengaluru -2(2), Bengaluru

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 390/BANG/2025[2015-16]Status: DisposedITAT Bangalore07 Jul 2025AY 2015-16

Bench: Shri Laxmi Prasad Sahu & Shri Prakash Chand Yadav

For Appellant: Smt. Tanmayee Rajkumar, A.RFor Respondent: Sri Aarshi Prasad, D.R
Section 143(3)Section 154Section 220(2)Section 222(2)Section 246(1)Section 246ASection 250

…h Section 250 and 251 of the Act. Be that as it may, it definitely falls within the appealable orders under Section 246(1) of the Act. No doubt, CIT(Appeals) has relied on the decision of Calcutta High Court in the case of ANZ Grindlays Bank PLC v. CIT [2000] 241 ITR 269/108 Taxman 328, which held that an order charging interest under section 220(2) was not appealable. Nevertheless, in the case of CIT v. Chika Overseas (P.) Ltd. [2012] 209 Taxman 456/23 taxmann.com 315, Bombay High Court had considered a tax-appeal assailing levy of interest under Section 220(2) of the Act. Since there are conflicting decisions o…

Visa Worldwide Pte. Limited, Singapore vs. Deputy Commissioner of Income-Tax (International Taxation), Bengaluru -2(2), Bengaluru

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 389/BANG/2025[2014-15]Status: DisposedITAT Bangalore07 Jul 2025AY 2014-15

Bench: Shri Laxmi Prasad Sahu & Shri Prakash Chand Yadav

For Appellant: Smt. Tanmayee Rajkumar, A.RFor Respondent: Sri Aarshi Prasad, D.R
Section 143(3)Section 154Section 220(2)Section 222(2)Section 246(1)Section 246ASection 250

…h Section 250 and 251 of the Act. Be that as it may, it definitely falls within the appealable orders under Section 246(1) of the Act. No doubt, CIT(Appeals) has relied on the decision of Calcutta High Court in the case of ANZ Grindlays Bank PLC v. CIT [2000] 241 ITR 269/108 Taxman 328, which held that an order charging interest under section 220(2) was not appealable. Nevertheless, in the case of CIT v. Chika Overseas (P.) Ltd. [2012] 209 Taxman 456/23 taxmann.com 315, Bombay High Court had considered a tax-appeal assailing levy of interest under Section 220(2) of the Act. Since there are conflicting decisions o…

Visa Worldwide Pte. Limited, Singapore vs. Deputy Commissioner of Income-Tax (International Taxation), Bengaluru -2(2), Bengaluru

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 388/BANG/2025[2013-14]Status: DisposedITAT Bangalore07 Jul 2025AY 2013-14

Bench: Shri Laxmi Prasad Sahu & Shri Prakash Chand Yadav

For Appellant: Smt. Tanmayee Rajkumar, A.RFor Respondent: Sri Aarshi Prasad, D.R
Section 143(3)Section 154Section 220(2)Section 222(2)Section 246(1)Section 246ASection 250

…h Section 250 and 251 of the Act. Be that as it may, it definitely falls within the appealable orders under Section 246(1) of the Act. No doubt, CIT(Appeals) has relied on the decision of Calcutta High Court in the case of ANZ Grindlays Bank PLC v. CIT [2000] 241 ITR 269/108 Taxman 328, which held that an order charging interest under section 220(2) was not appealable. Nevertheless, in the case of CIT v. Chika Overseas (P.) Ltd. [2012] 209 Taxman 456/23 taxmann.com 315, Bombay High Court had considered a tax-appeal assailing levy of interest under Section 220(2) of the Act. Since there are conflicting decisions o…

Visa Worldwide Pte. Limited, Singapore vs. Deputy Commissioner of Income-Tax (International Taxation), Bengaluru -2(2), Bengaluru

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 387/BANG/2025[2012-13]Status: DisposedITAT Bangalore07 Jul 2025AY 2012-13

Bench: Shri Laxmi Prasad Sahu & Shri Prakash Chand Yadav

For Appellant: Smt. Tanmayee Rajkumar, A.RFor Respondent: Sri Aarshi Prasad, D.R
Section 143(3)Section 154Section 220(2)Section 222(2)Section 246(1)Section 246ASection 250

…h Section 250 and 251 of the Act. Be that as it may, it definitely falls within the appealable orders under Section 246(1) of the Act. No doubt, CIT(Appeals) has relied on the decision of Calcutta High Court in the case of ANZ Grindlays Bank PLC v. CIT [2000] 241 ITR 269/108 Taxman 328, which held that an order charging interest under section 220(2) was not appealable. Nevertheless, in the case of CIT v. Chika Overseas (P.) Ltd. [2012] 209 Taxman 456/23 taxmann.com 315, Bombay High Court had considered a tax-appeal assailing levy of interest under Section 220(2) of the Act. Since there are conflicting decisions o…

Visa Worldwide Pte. Limited, Singapore vs. Deputy Commissioner of Income-Tax (International Taxation), Bengaluru -2(2), Bengaluru

In the result, all the appeals filed by the assessee are allowed for statistical purposes

ITA 386/BANG/2025[2011-12]Status: DisposedITAT Bangalore07 Jul 2025AY 2011-12

Bench: Shri Laxmi Prasad Sahu & Shri Prakash Chand Yadav

For Appellant: Smt. Tanmayee Rajkumar, A.RFor Respondent: Sri Aarshi Prasad, D.R
Section 143(3)Section 154Section 220(2)Section 222(2)Section 246(1)Section 246ASection 250

…h Section 250 and 251 of the Act. Be that as it may, it definitely falls within the appealable orders under Section 246(1) of the Act. No doubt, CIT(Appeals) has relied on the decision of Calcutta High Court in the case of ANZ Grindlays Bank PLC v. CIT [2000] 241 ITR 269/108 Taxman 328, which held that an order charging interest under section 220(2) was not appealable. Nevertheless, in the case of CIT v. Chika Overseas (P.) Ltd. [2012] 209 Taxman 456/23 taxmann.com 315, Bombay High Court had considered a tax-appeal assailing levy of interest under Section 220(2) of the Act. Since there are conflicting decisions o…

Bansila Mohanlal Malani Rep.by L/R Smt. Aruna Malani, Hyderabad vs. Income Tax Officer, Ward-10(1), Hyderabad

In the result, appeals of the assessee for both the AYs are treated as allowed for statistical purposes

ITA 1280/HYD/2018[1994-95]Status: DisposedITAT Hyderabad23 Oct 2019AY 1994-95

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

For Respondent: Sh. Chilaka Rajeswara Reddy, D.R
Section 132(4)Section 154Section 220(2)Section 234A

…f Bakelite Highlam Ltd. Vs. CIT reported in 171 ITR 344 (AP). 4. The Ld.DR, on the other hand, supported the orders of the CIT(A) and placed reliance upon the decision of Hon’ble High Court of Calcutta in the case of ANZ Grindlays Bank PLC vs. CIT reported on 241 ITR 269(2000) (Calcutta) wherein it has been held that the order charging interest u/s 220(2) of the Act is neither a part of assessment order, nor there is any appeal provided u/s 246 of the Act and, therefore, the order charging interest u/s 220(2) of the Act is not an appealable order. 5. Having regard to the rival contentions and material placed on r…

Bansila Mohanlal Malani Rep. by L/R Smt. Aruna Malani, Hyderabad vs. Income Tax Officer, Ward-10(1), Hyderabad

In the result, appeals of the assessee for both the AYs are treated as allowed for statistical purposes

ITA 1279/HYD/2018[1993-94]Status: DisposedITAT Hyderabad23 Oct 2019AY 1993-94

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

For Respondent: Sh. Chilaka Rajeswara Reddy, D.R
Section 132(4)Section 154Section 220(2)Section 234A

…f Bakelite Highlam Ltd. Vs. CIT reported in 171 ITR 344 (AP). 4. The Ld.DR, on the other hand, supported the orders of the CIT(A) and placed reliance upon the decision of Hon’ble High Court of Calcutta in the case of ANZ Grindlays Bank PLC vs. CIT reported on 241 ITR 269(2000) (Calcutta) wherein it has been held that the order charging interest u/s 220(2) of the Act is neither a part of assessment order, nor there is any appeal provided u/s 246 of the Act and, therefore, the order charging interest u/s 220(2) of the Act is not an appealable order. 5. Having regard to the rival contentions and material placed on r…