Bank of Rajasthan Ltd. v. Commissioner of Income Tax

2024 SCC OnLine SC 2877Reported decision2024#5633 most cited

What is Bank of Rajasthan Ltd. v. Commissioner of Income Tax authority for?

Banks can claim tax deductions for broken period interest on Held to Maturity (HTM) government securities if classified as stock-in-trade, treating it as revenue expenditure, not capital expenditure.

21

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2024 to 2026.

Also referred to as

Bank of Rajasthan Ltd. v. Commissioner of Income Tax · broken period interest · Held to Maturity · HTM securities · stock-in-trade · revenue expenditure · capital expenditure · Section 14A · Section 37(1) · Section 43D · Section 35D

Also reported as

167 Taxmann.com 430

Sections most often in play

Section 14ASection 37(1)Section 43DSection 35DSection 234ASection 41Section 8D(2)Section 143(3)
Read the full judgment

Issues it is cited on

section 43dsection 35dsection 41interest on securitiesinterest u/s 234arevenue expendituredisallowance u/s 14asection 43section 37(1)capital expendituresection 37disallowance under section 14a

Judgments citing Bank of Rajasthan Ltd. v. Commissioner of Income Tax

Assistant Commissioner, Mumbai vs. Idbi Bank Limited, Mumbai

In the result, the appeal of the revenue bearing ITA No

ITA 5250/MUM/2024[2020-21]Status: DisposedITAT Mumbai14 Nov 2024AY 2020-21

Bench: Shri. Anikesh Banerjee & Smt. Renu Jauhri

For Appellant: Shri Chellamani NareshFor Respondent: Shri Satya Pal Kumar CIT (DR)
Section 115JSection 14Section 143(3)Section 144BSection 14ASection 250Section 36

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “C”, MUMBAI BEFORE SHRI. ANIKESH BANERJEE, JUDICIAL MEMBER AND SMT. RENU JAUHRI, ACCOUNTANT MEMBER I.T.A No.5250/Mum/2024 (Assessment Year: 2020-21) Assistant Commissioner, vs Principal Officer, IDBI Bank Limited Mumbai, IDBI Bank, Mumbai-400 001 5th Room No.559, Floor, PAN: AABCI8842G Aayakar Bhavan, New Marine Lines, Mumbai-400 020 APPELLANT RESPONDENT Assessee by : Shri Chellamani Naresh Respondent by : Shri Satya Pal Kumar CIT (DR) Date of hearing : 13/11/2024 Date of pronouncement : 14/11/2024 O R D E R PER ANIKESH BANERJEE, J.M: Instant appeal of the…