Catholic Syrian Bank Ltd. v. ACIT

38 SOT 553Income Tax Appellate Tribunal2010#3192 most cited

What is Catholic Syrian Bank Ltd. v. ACIT authority for?

Amortization of premium on purchase of government securities is allowable as a deduction if it is in line with RBI's prudential norms and the assessee follows a consistent accounting system.

37

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2015 to 2025.

Also referred to as

Catholic Syrian Bank Ltd. v. ACIT · 38 SOT 553 · amortization of premium · government securities · RBI prudential norms · consistent accounting system · deduction · P&L account · Cochin ITAT

Sections most often in play

Section 145Section 36(1)(viia)Section 37(1)Section 145(1)Section 18Section 36(1)(vii)Section 143(3)Section 22(1)

Issues it is cited on

section 36(1)(via)section 145(1)section 22(1)section 36(1)(viia)right to receivesection 18interest on securitiessection 36(1)(vii)section 22mercantile system of accountingcommercial expediencysection 145

Judgments citing Catholic Syrian Bank Ltd. v. ACIT

Sri Varalakshmi Jute Twine Mills Private Limited, Rajam vs. DCIT, Circle-4(1), Visakhapatnam

In the result, appeals filed by the Revenue in ITA

ITA 404/VIZ/2017[2013-2014]Status: DisposedITAT Visakhapatnam09 Feb 2018AY 2013-2014

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bledcit, Circle-4(1), Vs. M/S. Sri Varalakshmi Jute Visakhapatnam. Twine Mills Pvt. Ltd., Bobbili Road, Rajam (Po), Srikakulam District. Pan No. Aadcs 1167 L Sri Varalakshmi Jute Twine Vs. Ito, Ward-3, Mills Pvt. Ltd., Bobbili Road, Srikakulam. Rajam (Po), Srikakulam Dist. Pan No. Aadcs 1167 L Acit, Circle-4(1), Vs. M/S. Sri Varalakshmi Jute Visakhapatnam. Twine Mills Pvt. Ltd., Bobbili Road, Rajam (Po), Srikakulam District. Pan No. Aadcs 1167 L Sri Varalakshmi Jute Twine Vs. Dcit, Circle-4(1), Mills Pvt. Ltd., Bobbili Road, Visakhapatnam. Rajam (Po), Srikakulam Dist. Pan No. Aadcs 1167 L (Appellants) (Respondents)

For Appellant: Shri Yogesh A. Thar &For Respondent: Shri T. Satyanandam – Sr.DR
Section 143(1)Section 143(3)

…429), Hon'ble Gujarat High Court in the case of CIT vs. Laxmi Cement Distributors (P) Ltd. 104 ITR 711; Hyderabad Tribunal decision in the case of A.P. Housing Board vs. DCIT (36 Taxmann.com 561), Cochin 1TAT in the case of Catholic Syrian Bank Ltd. vs. ACIT 38 SOT 553. 8.4 The authorized representative relied on the decision of the Hon'ble Supreme Court in the case of CIT v Chandulal Keshavlal & Co. (38 ITR 601 (SC)) and contended that expenditure incurred on the ground of commercial expediency and in order indirectly to facilitate the carrying on of the business is allowable. It was contended that the fact tha…

Sri Varalakshmi Jute Twine Mills Pvt. Ltd., Rajam vs. The ITO, Srikakulam

In the result, appeals filed by the Revenue in ITA

ITA 349/VIZ/2016[2012-2013]Status: DisposedITAT Visakhapatnam09 Feb 2018AY 2012-2013

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bledcit, Circle-4(1), Vs. M/S. Sri Varalakshmi Jute Visakhapatnam. Twine Mills Pvt. Ltd., Bobbili Road, Rajam (Po), Srikakulam District. Pan No. Aadcs 1167 L Sri Varalakshmi Jute Twine Vs. Ito, Ward-3, Mills Pvt. Ltd., Bobbili Road, Srikakulam. Rajam (Po), Srikakulam Dist. Pan No. Aadcs 1167 L Acit, Circle-4(1), Vs. M/S. Sri Varalakshmi Jute Visakhapatnam. Twine Mills Pvt. Ltd., Bobbili Road, Rajam (Po), Srikakulam District. Pan No. Aadcs 1167 L Sri Varalakshmi Jute Twine Vs. Dcit, Circle-4(1), Mills Pvt. Ltd., Bobbili Road, Visakhapatnam. Rajam (Po), Srikakulam Dist. Pan No. Aadcs 1167 L (Appellants) (Respondents)

For Appellant: Shri Yogesh A. Thar &For Respondent: Shri T. Satyanandam – Sr.DR
Section 143(1)Section 143(3)

…429), Hon'ble Gujarat High Court in the case of CIT vs. Laxmi Cement Distributors (P) Ltd. 104 ITR 711; Hyderabad Tribunal decision in the case of A.P. Housing Board vs. DCIT (36 Taxmann.com 561), Cochin 1TAT in the case of Catholic Syrian Bank Ltd. vs. ACIT 38 SOT 553. 8.4 The authorized representative relied on the decision of the Hon'ble Supreme Court in the case of CIT v Chandulal Keshavlal & Co. (38 ITR 601 (SC)) and contended that expenditure incurred on the ground of commercial expediency and in order indirectly to facilitate the carrying on of the business is allowable. It was contended that the fact tha…

The DCIT, Visakhapatnam vs. Sri Varalakshmi Jute Mills Pvt Ltd, Srikakulam

In the result, appeals filed by the Revenue in ITA

ITA 340/VIZ/2016[2012-2013]Status: DisposedITAT Visakhapatnam09 Feb 2018AY 2012-2013

Bench: Shri V. Durga Rao, Hon’Ble & Shri D.S. Sunder Singh, Hon’Bledcit, Circle-4(1), Vs. M/S. Sri Varalakshmi Jute Visakhapatnam. Twine Mills Pvt. Ltd., Bobbili Road, Rajam (Po), Srikakulam District. Pan No. Aadcs 1167 L Sri Varalakshmi Jute Twine Vs. Ito, Ward-3, Mills Pvt. Ltd., Bobbili Road, Srikakulam. Rajam (Po), Srikakulam Dist. Pan No. Aadcs 1167 L Acit, Circle-4(1), Vs. M/S. Sri Varalakshmi Jute Visakhapatnam. Twine Mills Pvt. Ltd., Bobbili Road, Rajam (Po), Srikakulam District. Pan No. Aadcs 1167 L Sri Varalakshmi Jute Twine Vs. Dcit, Circle-4(1), Mills Pvt. Ltd., Bobbili Road, Visakhapatnam. Rajam (Po), Srikakulam Dist. Pan No. Aadcs 1167 L (Appellants) (Respondents)

For Appellant: Shri Yogesh A. Thar &For Respondent: Shri T. Satyanandam – Sr.DR
Section 143(1)Section 143(3)

…429), Hon'ble Gujarat High Court in the case of CIT vs. Laxmi Cement Distributors (P) Ltd. 104 ITR 711; Hyderabad Tribunal decision in the case of A.P. Housing Board vs. DCIT (36 Taxmann.com 561), Cochin 1TAT in the case of Catholic Syrian Bank Ltd. vs. ACIT 38 SOT 553. 8.4 The authorized representative relied on the decision of the Hon'ble Supreme Court in the case of CIT v Chandulal Keshavlal & Co. (38 ITR 601 (SC)) and contended that expenditure incurred on the ground of commercial expediency and in order indirectly to facilitate the carrying on of the business is allowable. It was contended that the fact tha…

ACIT, Circle-48, Kolkata vs. Paschim Banga Gramin Bank, Howrah

In the result, the appeal of the revenue is dismissed

ITA 8/KOL/2015[2010-2011]Status: DisposedITAT Kolkata05 Jan 2018AY 2010-2011

Bench: Hon’Ble Shri J.Sudhakar Reddy, Am & Hon’Ble Shri A.T. Varkey, Jm ] I.T.A No. 8/Kol/2015 Assessment Year : 2010-11 Acit, Circle-48, Kolkata -Vs- Paschim Banga Gramin Bank [Pan: Aaajp 0923 H] (Appellant) (Respondent)

For Appellant: Shri G.Mallikarjuna, CIT DRFor Respondent: None
Section 143(3)Section 36(1)(viia)

…IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH : KOLKATA [Before Hon’ble Shri J.Sudhakar Reddy, AM & Hon’ble Shri A.T. Varkey, JM ] I.T.A No. 8/Kol/2015 Assessment Year : 2010-11 ACIT, Circle-48, Kolkata -vs- Paschim Banga Gramin Bank [PAN: AAAJP 0923 H] (Appellant) (Respondent) For the Appellant : Shri G.Mallikarjuna, CIT DR For the Revenue : None Date of Hearing : 04.12.2017 Date of Pronouncement : 05.01.2018 ORDER Per J.Sudhakar Reddy, AM This appeal by the Revenue arises out of the order of the Learned Commissioner of Income Tax (Appeals)-XXX, Kolkata [in short the ld CITA] dated 27.10.2014 against…

The West Bengal State Co Operative Bank Ltd, Kolkata vs. D.C.II.T Cir - 56, Kolkata

In the result, these grounds of the assessee are allowed for statistical purposes

ITA 746/KOL/2013[2009-10]Status: DisposedITAT Kolkata30 Nov 2017AY 2009-10
Section 139(1)Section 143(3)Section 37

…for in the accounts. The latest guidelines of the RBI may be referred to for allowing any such claims.” 13. Applying this circular of the CBDT, a similar claim was allowed by Cochin Bench of the Tribunal in the case of Catholic Syrian Bank Ltd. vs ACIT (2010) 38 SOT 553. Similar order passed by Panaji Bench of the Tribunal in the case of The Khanapur Co-op Bank Ltd. vs. ITO, ITA No. 141/PNJ/2011, dated 08.09.2011allowing amortisation of the premium paid on acquisition of HTM bonds. 14. Respectfully following the same, we allow this claim of the assessee and delete the disallowance. 15. In the result ground no 4 i…

M/S Suvarna Co-Operative Bank Ltd, Bangalore vs. Assistant Commissioner of Income-Tax, Bangalore

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 379/BANG/2017[2012-13]Status: DisposedITAT Bangalore31 Oct 2017AY 2012-13
For Appellant: Shri Lokesh Jain, CAFor Respondent: Shri M.K. Biju, JCIT (DR)

…T in ITA Nos. 1090(Bang.)/2010 & 7(Bang.)/2011 dated 11.05.2012, copy enclosed as per annexure – 3. c) The S.K. Dist. Central Vs. ACIT in ITA Nos. 3268-3269/Ahd/2015 dated 26.02.2016, copy enclosed as per annexure – 4. d) Catholic Syrian Bank Ltd. Vs. ACIT in 38 SOT 553 (Cochin) e) The Khanapur Co-op Bank Ltd. Vs. ITO in ITA No. 141/PNJ/2011 dated 08.09.2011, copy not enclosed. f) Corporation Bank Vs. ACIT in ITA No. 112/Bang/2008(Bang), copy not enclosed. The ld. DR of revenue supported the order of authorities below. 5. We have considered the rival submissions. We find that the AO has followed the judgment of…

Canara Bank, Bangalore vs. JCIT, Bangalore

In the result, the appeal filed by the revenue is dismissed

ITA 931/BANG/2016[2011-12]Status: DisposedITAT Bangalore15 Sept 2017AY 2011-12

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri G.Sarangan, Senior Advocate and Shri S.Ananthan, CAFor Respondent: Shri G.R. Reddy, CIT(DR)
Section 143(3)Section 36(1)(vii)

…see submitted that the Commissioner of Income-tax (Appeals) had failed to see the reason that a issue similar to that of the present one had been allowed by various benches of the Hon'ble Tribunals, namely : • Catholic Syrian Bank Ltd., v. ACIT – Cochin (2010)38 SOT 553 ; • Khanapur Coop.Bank Ltd., v. ITO ITA.141/PNJ/ 2011(Panaji); • Corporation Bank v. ACIT, M'lore in ITA.112/Bang/2008 (Bang) The learned counsel also placed reliance on Board's Instructions No.17 of 2008(vii) and pleaded that the claim of the assessee be allowed as the assessee had the powers to debit in its P&L account a sum of Rs.29,02 lakhs of…

Canara Bank, Bangalore vs. JCIT, Bangalore

In the result, the appeal filed by the revenue is dismissed

ITA 1493/BANG/2014[2010-11]Status: DisposedITAT Bangalore15 Sept 2017AY 2010-11

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri G.Sarangan, Senior Advocate and Shri S.Ananthan, CAFor Respondent: Shri G.R. Reddy, CIT(DR)
Section 143(3)Section 36(1)(vii)

…see submitted that the Commissioner of Income-tax (Appeals) had failed to see the reason that a issue similar to that of the present one had been allowed by various benches of the Hon'ble Tribunals, namely : • Catholic Syrian Bank Ltd., v. ACIT – Cochin (2010)38 SOT 553 ; • Khanapur Coop.Bank Ltd., v. ITO ITA.141/PNJ/ 2011(Panaji); • Corporation Bank v. ACIT, M'lore in ITA.112/Bang/2008 (Bang) The learned counsel also placed reliance on Board's Instructions No.17 of 2008(vii) and pleaded that the claim of the assessee be allowed as the assessee had the powers to debit in its P&L account a sum of Rs.29,02 lakhs of…

Joint Commissioner of Income Tax, Bangalore vs. M/S Canara Bank, Bangalore

In the result, the appeal filed by the revenue is dismissed

ITA 1440/BANG/2014[2010-11]Status: DisposedITAT Bangalore15 Sept 2017AY 2010-11

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri G.Sarangan, Senior Advocate and Shri S.Ananthan, CAFor Respondent: Shri G.R. Reddy, CIT(DR)
Section 143(3)Section 36(1)(vii)

…see submitted that the Commissioner of Income-tax (Appeals) had failed to see the reason that a issue similar to that of the present one had been allowed by various benches of the Hon'ble Tribunals, namely : • Catholic Syrian Bank Ltd., v. ACIT – Cochin (2010)38 SOT 553 ; • Khanapur Coop.Bank Ltd., v. ITO ITA.141/PNJ/ 2011(Panaji); • Corporation Bank v. ACIT, M'lore in ITA.112/Bang/2008 (Bang) The learned counsel also placed reliance on Board's Instructions No.17 of 2008(vii) and pleaded that the claim of the assessee be allowed as the assessee had the powers to debit in its P&L account a sum of Rs.29,02 lakhs of…

Canara Bank vs. Addl.C.I, .T

In the result, the appeal filed by the revenue is dismissed

ITA 979/BANG/2013[2009-10]Status: DisposedITAT Bangalore15 Sept 2017AY 2009-10

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri G.Sarangan, Senior Advocate and Shri S.Ananthan, CAFor Respondent: Shri G.R. Reddy, CIT(DR)
Section 143(3)Section 36(1)(vii)

…see submitted that the Commissioner of Income-tax (Appeals) had failed to see the reason that a issue similar to that of the present one had been allowed by various benches of the Hon'ble Tribunals, namely : • Catholic Syrian Bank Ltd., v. ACIT – Cochin (2010)38 SOT 553 ; • Khanapur Coop.Bank Ltd., v. ITO ITA.141/PNJ/ 2011(Panaji); • Corporation Bank v. ACIT, M'lore in ITA.112/Bang/2008 (Bang) The learned counsel also placed reliance on Board's Instructions No.17 of 2008(vii) and pleaded that the claim of the assessee be allowed as the assessee had the powers to debit in its P&L account a sum of Rs.29,02 lakhs of…

J.C.I.T vs. M/S Canara Bank

In the result, the appeal filed by the revenue is dismissed

ITA 1035/BANG/2013[2009-10]Status: DisposedITAT Bangalore15 Sept 2017AY 2009-10

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri G.Sarangan, Senior Advocate and Shri S.Ananthan, CAFor Respondent: Shri G.R. Reddy, CIT(DR)
Section 143(3)Section 36(1)(vii)

…see submitted that the Commissioner of Income-tax (Appeals) had failed to see the reason that a issue similar to that of the present one had been allowed by various benches of the Hon'ble Tribunals, namely : • Catholic Syrian Bank Ltd., v. ACIT – Cochin (2010)38 SOT 553 ; • Khanapur Coop.Bank Ltd., v. ITO ITA.141/PNJ/ 2011(Panaji); • Corporation Bank v. ACIT, M'lore in ITA.112/Bang/2008 (Bang) The learned counsel also placed reliance on Board's Instructions No.17 of 2008(vii) and pleaded that the claim of the assessee be allowed as the assessee had the powers to debit in its P&L account a sum of Rs.29,02 lakhs of…

ACIT, Gulbarga vs. M/S Krishna Grameena Bank, Gulbarga

In the result, the appeal of Revenue is partly allowed

ITA 592/BANG/2014[2010-11]Status: DisposedITAT Bangalore06 May 2016AY 2010-11

Bench: Shri Sunil Kumar Yadav & Shri A.K. Garodiaassessment Year : 2010-11

For Appellant: Shri Sanjay Kumar, CIT-III(DR)For Respondent: Shri G. Venkatesh, Advocate
Section 43B

…IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH : BANGALORE BEFORE SHRI SUNIL KUMAR YADAV, JUDICIAL MEMBER AND SHRI A.K. GARODIA, ACCOUNTANT MEMBER Assessment year : 2010-11 The Assistant Commissioner of Vs. M/s. Krishna Grameena Bank, Income Tax, Head Office, Circle 1, Kusnoor Road, Gulbarga. Gulbarga. PAN: AAGFK 6964K APPELLANT RESPONDENT Appellant by : Shri Sanjay Kumar, CIT-III(DR) Respondent by : Shri G. Venkatesh, Advocate Date of hearing : 01.04.2016 Date of Pronouncement : 06.05.2016 O R D E R Per A.K. Garodia, Accountant Member This is Revenue’s appeal directed against the order of ld. CIT (Appeals)…

Asst.C.I.T., Mangalore vs. M/S the South Canara District Central Co-Operative Bank Ltd., Mangalore

In the result, the appeal filed by the revenue is dismissed

ITA 1195/BANG/2015[2012-13]Status: DisposedITAT Bangalore09 Mar 2016AY 2012-13

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri S. Ramasubramanian, CAFor Respondent: Mrs. Neera Malhotra, CIT-II
Section 144Section 194A(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL BANGALORE BENCH ‘B’, BANGALORE BEFORE SHRI VIJAY PAL RAO, JUDICIAL MEMBER AND SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER ITA No.1195(B)/2015 (Assessment year : 2012-13) The Assistant Commissioner of Income-tax, Circle-2(1), Mangalore Appellant Vs M/s South Canara District Central Co-Op.Bank Ltd., Sadashiva Sahakara Sadana, K.S.Rao Road, Mangalore-575 002. Pan No.AABAT6621N Respondent Revenue by : Mrs. Neera Malhotra, CIT-II Assessee by : Shri S. Ramasubramanian, CA Date of hearing : 03-03-2016 Date of pronouncement : 09-03-2016 O R D E R PER SHRI VIJAY PAL RAO, JM: T…

Assistant Commissioner of Income Tax, Tumkur vs. M/S Tumkur Veerashiva Co.Operative Bank Ltd, Tumkur

In the result, the Revenue appeal is partly allowed for statistical purpose

ITA 1174/BANG/2014[2010-11]Status: DisposedITAT Bangalore16 Oct 2015AY 2010-11

Bench: Shri Vijaypal Rao & Shri G Manjunathathe Asst. Commissioner Of Income-Tax, Circle-1, Tumkur. . Appellant Vs. M/S Tumkur Veerashiva Co-Operative Bank Ltd., Dr. Radhkrishna Road, Ss Puram, Tumkur. . Respondent Appellant By : Shri Pk Srihari, Addl. Cit, Respondent By : Shri None Date Of Hearing : 08-10-2015 Date Of Pronouncement : 16-10-2015 O R D E R

For Appellant: Shri PK Srihari, Addl. CITFor Respondent: Shri None
Section 142(1)Section 143(2)Section 143(3)Section 37

…g as under: “08. We have carefully considered the rival submissions and perused the relevant facts and materials on record. We have also considered the findings of the various benches of the Tribunal, as under : (i) Catholic Syrian Bank Ltd v. ACIT – (2010) 38 SOT 553 (Coch): An identical issue to that of the subject matter under consideration had arisen before the Cochin Bench. After analyzing the issue in depth, the bench has observed that with regard to amortization of premium on purchase of Government securities, it was clarified that this was made as per the prudential norms of the RBI. Following the Tribu…

ACIT, Hubli vs. The Sirsi Urban Sahakari Bank Ltd., Sirsi

In the result, Revenue’s appeal for Assessment Year 2010-11 is treated as partly allowed for statistical purposes

ITA 626/BANG/2014[2010-11]Status: DisposedITAT Bangalore08 Apr 2015AY 2010-11

Bench: Shri N.V. Vasudevan & Shri Jason P. Boaz

For Appellant: Dr. P.K. Srihari, Addl. CIT (D.R)For Respondent: Shri S. Ramasubramanian, C.A
Section 143(3)Section 14ASection 36(1)(vii)Section 40

…hereunder :- “ 8. We have carefully considered the rival submissions and perused the relevant facts and materials on record. We have also considered the findings of the various benches of the Tribunal, as under : (i) Catholic Syrian Bank Ltd v. ACIT – (2010) 38 SOT 553 (Cochin) : An identical issue to that of the subject matter under consideration had arisen before the Cochin Bench. After analyzing the issue in depth, the bench has observed that with regard to amortization of premium on purchase of Government securities, it was clarified that this was made as per the prudential norms of the RBI. Following the Tr…

DCIT vs. Ing Vysya Bank, Bangalore

In the result, appeal by the Assessee is partly allowed while the 68

ITA 318/BANG/2013[2005-06]Status: DisposedITAT Bangalore06 Feb 2015AY 2005-06

Bench: Shri N.V. Vasudevan & Shri Abraham P. Georgeassessment Year : 2005-06 M/S. Ing Vysya Bank Ltd., Vs. The Assistant Commissioner Of Ing Vysya House, Income Tax, No.22, M.G. Road, Circle 11(4), Bangalore – 560 001. Bangalore. Pan: Aabct 0529M Appellant Respondent Assessment Year : 2005-06 The Deputy Commissioner Of Vs. M/S. Ing Vysya Bank Ltd., Income Tax, Bangalore – 560 001. Circle 11(4), Pan: Aabct 0529M Bangalore. Appellant Respondent Assessee By : Shri S. Ananthan, C.A. Revenue By : Shri C.H. Sundar Rao, Cit-I(Dr) Date Of Hearing : 20.01.2015 Date Of Pronouncement : 06.02.2015 O R D E R Per N.V. Vasudevan

For Appellant: Shri S. Ananthan, C.AFor Respondent: Shri C.H. Sundar Rao, CIT-I(DR)
Section 1Section 10Section 234D

…the assessee. 08. We have carefully considered the rival submissions and perused the relevant facts and materials on record. We have also considered the findings of the various benches of the Tribunal, as under : (i) Catholic Syrian Bank Ltd v. ACIT – (2010) 38 SOT 553 (Coch) : An identical issue to that of the subject matter under consideration had arisen before the Cochin Bench. After analyzing the issue in depth, the bench has observed that with regard to amortization of premium on purchase of Government securities, it was clarified that this was made as per the prudential norms of the RBI. Following the Trib…

Ing Vysya Bank Ltd vs. ACIT, Bangalore

In the result, appeal by the Assessee is partly allowed while the 68

ITA 288/BANG/2013[2005-06]Status: DisposedITAT Bangalore06 Feb 2015AY 2005-06

Bench: Shri N.V. Vasudevan & Shri Abraham P. Georgeassessment Year : 2005-06 M/S. Ing Vysya Bank Ltd., Vs. The Assistant Commissioner Of Ing Vysya House, Income Tax, No.22, M.G. Road, Circle 11(4), Bangalore – 560 001. Bangalore. Pan: Aabct 0529M Appellant Respondent Assessment Year : 2005-06 The Deputy Commissioner Of Vs. M/S. Ing Vysya Bank Ltd., Income Tax, Bangalore – 560 001. Circle 11(4), Pan: Aabct 0529M Bangalore. Appellant Respondent Assessee By : Shri S. Ananthan, C.A. Revenue By : Shri C.H. Sundar Rao, Cit-I(Dr) Date Of Hearing : 20.01.2015 Date Of Pronouncement : 06.02.2015 O R D E R Per N.V. Vasudevan

For Appellant: Shri S. Ananthan, C.AFor Respondent: Shri C.H. Sundar Rao, CIT-I(DR)
Section 1Section 10Section 234D

…the assessee. 08. We have carefully considered the rival submissions and perused the relevant facts and materials on record. We have also considered the findings of the various benches of the Tribunal, as under : (i) Catholic Syrian Bank Ltd v. ACIT – (2010) 38 SOT 553 (Coch) : An identical issue to that of the subject matter under consideration had arisen before the Cochin Bench. After analyzing the issue in depth, the bench has observed that with regard to amortization of premium on purchase of Government securities, it was clarified that this was made as per the prudential norms of the RBI. Following the Trib…