Bank of Rajasthan v. CIT

ACIT, CIRCLE-2(1)(1), MUMBAI vs. M/S BANK OF INDIA, MUMBAI

In the result, the appeal by the Revenue for the assessment year 2018-

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailita No.1452/Mum/2023 Assessment Year : 2016-17 Assessment Year : 2018-19

…w by a higher judicial forum, we approve the conclusions arrived at by the learned CIT(A) and decline to interfere in the matter. 57. Ground no. 1 is thus dismissed.” 51. We find that the Hon’ble Supreme Court in Bank of Rajasthan vs. CIT, reported in (2024) 469 ITR 280 (SC) held that where an assessee bank purchase government security and paid broken period interest since said securities was treated as stock-in-trade, the broken period interest could not be considered as capital asset and would have to be treated as revenue expenditure. 52. Therefore, in view of the aforesaid findings and respectfully followin…

BANK OF INDIA,MUMBAI vs. ACIT-2(1)(2), MUMBAI

In the result, the appeal by the Revenue for the assessment year 2018-

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailita No.1452/Mum/2023 Assessment Year : 2016-17 Assessment Year : 2018-19

…w by a higher judicial forum, we approve the conclusions arrived at by the learned CIT(A) and decline to interfere in the matter. 57. Ground no. 1 is thus dismissed.” 51. We find that the Hon’ble Supreme Court in Bank of Rajasthan vs. CIT, reported in (2024) 469 ITR 280 (SC) held that where an assessee bank purchase government security and paid broken period interest since said securities was treated as stock-in-trade, the broken period interest could not be considered as capital asset and would have to be treated as revenue expenditure. 52. Therefore, in view of the aforesaid findings and respectfully followin…

CENTRAL BANK OF INDIA,MUMBAI vs. CIT(A)-3, MUMBAI

In the result, the appeal by the Revenue for the

…in favour of the assessee, followed the decision of the Hon'ble\njurisdictional High Court in CIT v/s HDFC Bank Ltd, in ITA No. 330 of 2012.\nWe find that the Hon'ble Supreme Court in Bank of Rajasthan Ltd. vs.\nCommissioner of Income-tax, reported in [2024] 469 ITR 280 (SC), held that\nCentral Bank of India (A.Y. 2013-14 to 2016-17) 23\nwhere assessee-bank purchased government securities and paid broken\nperiod interest, since said securities were treated as stock-in-trade, broken\nperiod interest could not be considered as capital expenditure and would have\nto be treated as revenue expenditure, which could be…

JT. CIT (OSD) -2(1)(2), MUMBAI vs. CENTRAL BANK OF INDIA, MUMBAI

In the result, the appeal by the Revenue for the

…in favour of the assessee, followed the decision of the Hon'ble\njurisdictional High Court in CIT v/s HDFC Bank Ltd, in ITA No. 330 of 2012.\nWe find that the Hon'ble Supreme Court in Bank of Rajasthan Ltd. vs.\nCommissioner of Income-tax, reported in [2024] 469 ITR 280 (SC), held that\n\nCentral Bank of India (A.Y. 2013-14 to 2016-17) 24\n\nwhere assessee-bank purchased government securities and paid broken\nperiod interest, since said securities were treated as stock-in-trade, broken\nperiod interest could not be considered as capital expenditure and would have\nto be treated as revenue expenditure, which coul…

DCIT 2(1)(1), MUMBAI vs. CENTRAL BANK OF INDIA, MUMBAI

In the result, the appeal by the Revenue for the

…in favour of the assessee, followed the decision of the Hon'ble\njurisdictional High Court in CIT v/s HDFC Bank Ltd, in ITA No. 330 of 2012.\nWe find that the Hon'ble Supreme Court in Bank of Rajasthan Ltd. vs.\nCommissioner of Income-tax, reported in [2024] 469 ITR 280 (SC), held that\nCentral Bank of India (A.Y. 2013-14 to 2016-17) 23\nwhere assessee-bank purchased government securities and paid broken\nperiod interest, since said securities were treated as stock-in-trade, broken\nperiod interest could not be considered as capital expenditure and would have\nto be treated as revenue expenditure, which could be…

CENTRAL BANK OF INDIA,MUMBAI vs. ACIT - 2(1)(2), MUMBAI

In the result, the appeal by the Revenue for the

…in favour of the assessee, followed the decision of the Hon'ble\njurisdictional High Court in CIT v/s HDFC Bank Ltd, in ITA No. 330 of 2012.\nWe find that the Hon'ble Supreme Court in Bank of Rajasthan Ltd. vs.\nCommissioner of Income-tax, reported in [2024] 469 ITR 280 (SC), held that\nCentral Bank of India (A.Y. 2013-14 to 2016-17) 24\nwhere assessee-bank purchased government securities and paid broken\nperiod interest, since said securities were treated as stock-in-trade, broken\nperiod interest could not be considered as capital expenditure and would have\nto be treated as revenue expenditure, which could be…

ASSISTANT COMMISSIONER OF INCOME TAX 3(4),MUMBAI, AAYKAR BHAVAN vs. IDBI BANK LTD, PARTH PLAZAMORBI

In the result, all the aforesaid appeals of the Revenue and CO of the assessee are dismissed

Bench: Shri Sandeep Gosain & Shri Prabhash Shankarआयकर अपील सं./Ita Nos.5900, 5958 & 5959/Mum/2024 (निर्धारण वर्ा / Assessment Years : 2021-22, 2018-19 & 2013-14) Assistant Commissioner Of Vs. Idbi Bank Ltd., Income Tax -3(4), Apulki Cornermenon, Mumbai Piston Compound, Toap 416122, Kolhapur Maharashtra स्थायी लेखा सं./Pan No. : Aabci8842G (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) प्रत्याक्षेप सं../C.O. No.280/Mum/2024 (Arising Out Of Ita No. 5959/Mum/2024) Assessment Year: 2013-14 Idbi Bank Ltd., Vs. Assistant Commissioner Apulki Cornermenon, Of Income Tax -3(4), Piston Compound, Mumbai Toap 416122, Kolhapur Maharashtra स्थायी लेखा सं./Pan No. : Aabci8842G (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent)

…IN THE INCOME TAX APPELLATE TRIBUNAL “C’ BENCH MUMBAI BEFORE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER आयकर अपील सं./ITA Nos.5900, 5958 & 5959/MUM/2024 (निर्धारण वर्ा / Assessment Years : 2021-22, 2018-19 and 2013-14) Assistant Commissioner of Vs. IDBI Bank Ltd., Income Tax -3(4), Apulki Cornermenon, Mumbai Piston Compound, TOAP 416122, Kolhapur Maharashtra स्थायी लेखा सं./PAN No. : AABCI8842G (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) प्रत्याक्षेप सं../C.O. No.280/MUM/2024 (Arising out of ITA No. 5959/MUM/2024) Assessment Year: 2013-14 IDBI Bank Ltd., Vs. Assistan…

ACIT 3(4), MUMBAI, MUMBAI vs. IDBI BANK LIMITED, MUMBAI

In the result, all the aforesaid appeals of the Revenue and CO of the assessee are dismissed

Bench: Shri Sandeep Gosain & Shri Prabhash Shankarआयकर अपील सं./Ita Nos.5900, 5958 & 5959/Mum/2024 (निर्धारण वर्ा / Assessment Years : 2021-22, 2018-19 & 2013-14) Assistant Commissioner Of Vs. Idbi Bank Ltd., Income Tax -3(4), Apulki Cornermenon, Mumbai Piston Compound, Toap 416122, Kolhapur Maharashtra स्थायी लेखा सं./Pan No. : Aabci8842G (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) प्रत्याक्षेप सं../C.O. No.280/Mum/2024 (Arising Out Of Ita No. 5959/Mum/2024) Assessment Year: 2013-14 Idbi Bank Ltd., Vs. Assistant Commissioner Apulki Cornermenon, Of Income Tax -3(4), Piston Compound, Mumbai Toap 416122, Kolhapur Maharashtra स्थायी लेखा सं./Pan No. : Aabci8842G (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent)

…IN THE INCOME TAX APPELLATE TRIBUNAL “C’ BENCH MUMBAI BEFORE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER आयकर अपील सं./ITA Nos.5900, 5958 & 5959/MUM/2024 (निर्धारण वर्ा / Assessment Years : 2021-22, 2018-19 and 2013-14) Assistant Commissioner of Vs. IDBI Bank Ltd., Income Tax -3(4), Apulki Cornermenon, Mumbai Piston Compound, TOAP 416122, Kolhapur Maharashtra स्थायी लेखा सं./PAN No. : AABCI8842G (अपीलधर्थी /Appellant) .. (प्रत्यर्थी / Respondent) प्रत्याक्षेप सं../C.O. No.280/MUM/2024 (Arising out of ITA No. 5959/MUM/2024) Assessment Year: 2013-14 IDBI Bank Ltd., Vs. Assistan…

ACIT CIR 2(1)(1), MUMBAI vs. BANK OF BARODA, MUMBAI

In the result, the appeal by the Revenue is dismissed

Bench: Shri Amarjit Singhshri Sandeep Singh Karhailbank Of Baroda, C-26, G-Block, Baroda Corporate Centre, Bandra Kurla Complex, Bandra (East), Mumbai-400051. ……………. Appellant Pan: Aaacb 1534 F V/S Acit, 2(1)(1), ……………. Respondent Mumbai-400051. Acit, Circle - 2(1)(1), Room No. 561, 5Th Floor, Aayakar Bhavan, M.K. Road, ……………. Appellant Mumbai-400020. V/S Bank Of Baroda, C-26, G-Block, Baroda Corporate Centre, Bandra ……………. Respondent Kurla Complex, Bandra (East), Mumbai-400051. Pan: Aaacb 1534 F

…d order. 17. Accordingly, respectfully following the precedent as above, we uphold the order of learned CIT(A) and dismiss the ground raised by the Revenue." 35. We further find that recently the Hon’ble Supreme Court in Bank of Rajasthan Ltd. v. CIT, (2024) 469 ITR 280 (SC) held that where assessee bank purchased Government securities and paid broken period of interest, since said securities were treated as stock in trade, the broken period interest could not be considered as capital expenditure and would have to be treated as revenue expenditure. 36. Therefore, in view of the aforesaid findings and respectful…

BANK OF BARODA,MUMBAI vs. ACIT 2 (1)(1), MUMBAI

In the result, the appeal by the Revenue is dismissed

…der.\n17. Accordingly, respectfully following the precedent as above, we uphold the\norder of learned CIT(A) and dismiss the ground raised by the Revenue.\"\n35. We further find that recently the Hon'ble Supreme Court in Bank of\nRajasthan Ltd. v. CIT, (2024) 469 ITR 280 (SC) held that where assessee\nbank purchased Government securities and paid broken period of interest,\nsince said securities were treated as stock in trade, the broken period\ninterest could not be considered as capital expenditure and would have to be\ntreated as revenue expenditure.\n36. Therefore, in view of the aforesaid findings and respec…