CIT v. Bank of Rajasthan Ltd.

316 ITR 391High Court2009#2261 most cited

What is CIT v. Bank of Rajasthan Ltd. authority for?

Broken period interest paid on the purchase of securities constitutes capital expenditure and is therefore not allowable as a revenue deduction.

51

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2015 to 2025.

Also referred to as

CIT v Bank of Rajasthan Ltd · 316 ITR 391 · broken period interest deduction · interest on securities purchase · capital expenditure · revenue expenditure · disallowance of interest · deductibility of broken period interest · income tax deduction

Sections most often in play

Section 14ASection 36(1)(vii)Section 36(1)(viii)Section 40A(9)Section 41(4)
Read the full judgment

Issues it is cited on

section 57(i)section 2(d)section 90(3)section 2(26)section 129(1)section 2(17)section 43dsection 36(2)(v)section 5(c)section 41(4)section 36(1)(viia)section 46

Judgments citing CIT v. Bank of Rajasthan Ltd.

DCIT 2 (3)(2), Mumbai vs. M/S Bank of Madura Ltd [Now Merged With M/S Icici Bank Ltd], Mumbai

In the result, the appeals filed by the Revenue stands dismissed

ITA 5681/MUM/2019[1999-2000]Status: DisposedITAT Mumbai17 Mar 2021AY 1999-2000

…he Ld.CIT(A) erred in deleting the disallowance of broken period interest on purchase of securities by holding this expenditure deductible as business expenditure ignoring the judgment in the case of Commissioner of Income Tax Vs Bank of Rajasthan Ltd. (2009) 316 ITR 391, which decided the issue in favour of the Revenue.?" [ Tax Effect :Rs. 1,76,98,2 53] ITA Nos. 5680 & 5681/Mum/2019 Assessment Years: 1995-96 & 1999-2000 Page 2 of 6 2. "Whether on the facts and the circumstances of the case and in law, the Ld.ClT(A) erred in treating the Govt Securities held by the bank as Stock in Trade and allowing the deprec…

DCIT Circle-2(3)(2), Mumbai vs. M/S Bank of Madura Ltd. [Now Merged With M/S Icici Bank Ltd], Mumbai

In the result, the appeals filed by the Revenue stands dismissed

ITA 5680/MUM/2019[1995-1996]Status: DisposedITAT Mumbai17 Mar 2021AY 1995-1996

…he Ld.CIT(A) erred in deleting the disallowance of broken period interest on purchase of securities by holding this expenditure deductible as business expenditure ignoring the judgment in the case of Commissioner of Income Tax Vs Bank of Rajasthan Ltd. (2009) 316 ITR 391, which decided the issue in favour of the Revenue.?" [ Tax Effect :Rs. 1,76,98,2 53] ITA Nos. 5680 & 5681/Mum/2019 Assessment Years: 1995-96 & 1999-2000 Page 2 of 6 2. "Whether on the facts and the circumstances of the case and in law, the Ld.ClT(A) erred in treating the Govt Securities held by the bank as Stock in Trade and allowing the deprec…

State Bank of India (Successor to State Bank of Bikaner & Jaipur), Mumbai vs. ACIT -Circle 2(2)(1), Mumbai

Appeal stand allowed for statistical purposes

ITA 2824/MUM/2018[2014-15]Status: DisposedITAT Mumbai03 Mar 2021AY 2014-15

Bench: Hon’Ble Shri Mahavir Singh, Vp & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri C.Naresh-Ld.ARFor Respondent: Shri Jayant Jhaveri-Ld.CIT-DR
Section 143(3)Section 14A

…as right in deleting the addition of Rs.643,51,48,054/- holding that the broken period interest on purchase of securities is deductible as business expenditure ignoring the judgment of the case of Commissioner of Income Tax V/s. Bank of Rajasthan Ltd. (2009) (316 ITR 391) which decided the issue in favour of the Revenue? 2. The learned counsel for Assessee, Shri C. Naresh, at the outset, submitted that the issues of cross-appeals stood squarely adjudicated by Tribunal in assessee’s own case for AY 2008-09, ITA Nos.3644/Mum/2016 & 4563/Mum/2016 order dated 03/02/2020. A copy of the order has been placed on record.…

The Commissioner of Income Tax vs. State Bank of India(Sbi)

In the result, the appeals fail and are hereby

ITA/27/2013HC Karnataka08 Sept 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 260Section 260A

…1 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 8TH DAY OF SEPTEMBER 2020 PRESENT THE HON’BLE MR. JUSTICE ALOK ARADHE AND THE HON’BLE MR. JUSTICE H.T.NARENDRA PRASAD I.T.A. NO.27 OF 2013 C/W I.T.A. NO.26 OF 2013 I.T.A. NO.27 OF 2013 BETWEEN: 1. THE COMMISSIONER OF INCOME-TAX LTU, JSS TOWERS BSK III STAGE, BANGALORE. 2. THE COMMISSIONER OF INCOME-TAX (APPEALS) LTU, JSS TOWERS BSK III STAGE, BANGALORE. ... APPELLANTS (BY SRI. K.V. ARAVIND, ADV.,) AND: STATE BANK OF INDIA (SBI) HEAD OFFICE, P.B. NO.9727 K.G. ROAD, BANGALORE. ... RESPONDENT (B…

The Commissioner of Income Tax vs. State Bank of India(Sbi)

In the result, the appeals fail and are hereby

ITA/26/2013HC Karnataka08 Sept 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 260Section 260A

…1 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 8TH DAY OF SEPTEMBER 2020 PRESENT THE HON’BLE MR. JUSTICE ALOK ARADHE AND THE HON’BLE MR. JUSTICE H.T.NARENDRA PRASAD I.T.A. NO.27 OF 2013 C/W I.T.A. NO.26 OF 2013 I.T.A. NO.27 OF 2013 BETWEEN: 1. THE COMMISSIONER OF INCOME-TAX LTU, JSS TOWERS BSK III STAGE, BANGALORE. 2. THE COMMISSIONER OF INCOME-TAX (APPEALS) LTU, JSS TOWERS BSK III STAGE, BANGALORE. ... APPELLANTS (BY SRI. K.V. ARAVIND, ADV.,) AND: STATE BANK OF INDIA (SBI) HEAD OFFICE, P.B. NO.9727 K.G. ROAD, BANGALORE. ... RESPONDENT (B…

Dcb Bank Limited, Mumbai vs. Assistant Commissioner of Income Tax 2(3)(1), Mumbai

In the result, the appeal filed by the assessee is allowed

ITA 785/MUM/2018[2014-15]Status: DisposedITAT Mumbai29 Jul 2019AY 2014-15

Bench: Shri Ravish Sood () & Shri N.K. Pradhan () Assessment Year: 2014-15 Acit-2(3)(1), R.No. 552, 5Th M/S Dcb Bank Ltd. Floor, Aayakar Bhavan, M.K. Vs. (Formerly Development Road, Mumbai-400020. Credit Card Ltd.) 6Th Floor, Tower A, Peninsula Business Park, Senapati Bapat Marg, Lower Parel, Mumbai-400013. Pan No. Aaacd1461F Appellant Respondent Assessment Year: 2014-15 M/S Dcb Bank Ltd. Acit-2(3)(1), R.No. 552, (Formerly Development Vs. 5Th Floor, Aayakar Bhavan, Credit Card Ltd.) 6Th Floor, M.K. Road, Mumbai- Tower A, Peninsula 400020. Business Park, Senapati Bapat Marg, Lower Parel, Mumbai-400013 Pan No. Aaacd1461F Appellant Respondent

For Appellant: Mr. Satish Mody, ARFor Respondent: Mr. Rajesh Ojha, DR
Section 143(3)Section 28

…s) and not as investments for the purpose of income tax. Relying on the decision in the case of American Express International Banking Corporation v. CIT 258 ITR 601 (Bom), CIT v. Citibank NA (Civil Appeal No. 1549 of 2006) (SC), CIT v. Bank of Rajasthan Ltd. 316 ITR 391 (Raj) M/s DCB Bank Ltd. and the order of the Tribunal in assessee’s own case for AY 2010-11, the Ld. counsel submits that the addition made by the AO on the above be deleted. 6. We have heard the rival submissions and perused the relevant materials on record. In the case of Citibank NA (supra), the Hon’ble Supreme Court observed that the broken…

Assistant Commissioner of Income Tax 2(3)(1), Mumbai vs. Dcb Bank Limited (Formerly Development Credit Bank Limited), Mumbai

In the result, the appeal filed by the assessee is allowed

ITA 707/MUM/2018[2014-15]Status: DisposedITAT Mumbai29 Jul 2019AY 2014-15

Bench: Shri Ravish Sood () & Shri N.K. Pradhan () Assessment Year: 2014-15 Acit-2(3)(1), R.No. 552, 5Th M/S Dcb Bank Ltd. Floor, Aayakar Bhavan, M.K. Vs. (Formerly Development Road, Mumbai-400020. Credit Card Ltd.) 6Th Floor, Tower A, Peninsula Business Park, Senapati Bapat Marg, Lower Parel, Mumbai-400013. Pan No. Aaacd1461F Appellant Respondent Assessment Year: 2014-15 M/S Dcb Bank Ltd. Acit-2(3)(1), R.No. 552, (Formerly Development Vs. 5Th Floor, Aayakar Bhavan, Credit Card Ltd.) 6Th Floor, M.K. Road, Mumbai- Tower A, Peninsula 400020. Business Park, Senapati Bapat Marg, Lower Parel, Mumbai-400013 Pan No. Aaacd1461F Appellant Respondent

For Appellant: Mr. Satish Mody, ARFor Respondent: Mr. Rajesh Ojha, DR
Section 143(3)Section 28

…s) and not as investments for the purpose of income tax. Relying on the decision in the case of American Express International Banking Corporation v. CIT 258 ITR 601 (Bom), CIT v. Citibank NA (Civil Appeal No. 1549 of 2006) (SC), CIT v. Bank of Rajasthan Ltd. 316 ITR 391 (Raj) M/s DCB Bank Ltd. and the order of the Tribunal in assessee’s own case for AY 2010-11, the Ld. counsel submits that the addition made by the AO on the above be deleted. 6. We have heard the rival submissions and perused the relevant materials on record. In the case of Citibank NA (supra), the Hon’ble Supreme Court observed that the broken…

Deputy Commissioner of Income-Tax vs. Lokmangal Co-Op. Bank Ltd

In the result, C.O. No.101/PN/2014 in the case of Lokmangal Co-op

ITA 1097/PUN/2016[2011-12]Status: DisposedITAT Pune20 Jul 2018AY 2011-12

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

For Appellant: Shri S. N. PuranikFor Respondent: Shri Mukesh Jha
Section 43D

…usion, the Assessing Officer relied upon the ratio of the judgement of the Hon‟ble Supreme Court in the case of Vijaya Bank Ltd. vs. CIT, 187 ITR 541 (SC) as also the judgement of the Hon‟ble Rajasthan High Court in the case of CIT vs. Bank of Rajasthan Ltd., 316 ITR 391. 15. The CIT(A) has also affirmed the aforesaid stand of the Assessing Officer. The CIT(A) followed the judgement of the Hon‟ble Rajasthan High Court in the case of Bank of Rajasthan Ltd. (supra), which had dissented from the judgement of the Hon‟ble Bombay High Court in the case of American Express International Banking Corporation vs. CIT, 258…

DCIT Cen Cir 3(3) Cen RG 3, Mumbai vs. Sharekhan Ltd, Mumbai

ITA 1187/MUM/2017[2012-13]Status: DisposedITAT Mumbai03 Jul 2018AY 2012-13

Bench: Shri Joginder Singh & Shri N.K. Pradhan

Section 14ASection 36(1)(iii)

…TD. [2009] 313 ITR 340 (Bom) ,AMERICAN EXPRESS INTERNATIONAL BANKING CORPORATION v. CIT [2002] 258 ITR 601 (Bom) and CIT v. LORD KRISHNA BANK LTD. [2014] 366 ITR 416 (Bom). The Hon'ble Court also considered the cases of CIT v. Bank of Rajasthan Ltd. [2009] 316 ITR 391 (Raj) (para 2)CIT v. Reliance Utilities and Power Ltd. [2009] 313 ITR 340 (Bom) (para 4) CIT v. Lord Krishna Bank Ltd. [2014] 366 ITR 416 (Bom) (para 7) East India Pharmaceutical Works Ltd. v. CIT [1997] 224 ITR 627 (SC) (para 4)Southern Technologies Ltd. v. Joint CIT [2010] 320 ITR 577 (SC) (para 2)Vijaya Bank Ltd. v. Addl. CIT [1991] 187…

DCIT Cen Cir 3(3) Cen RG 3, Mumbai vs. Sharekhan Ltd, Mumbai

ITA 1188/MUM/2017[2013-14]Status: DisposedITAT Mumbai03 Jul 2018AY 2013-14

Bench: Shri Joginder Singh & Shri N.K. Pradhan

Section 14ASection 36(1)(iii)

…TD. [2009] 313 ITR 340 (Bom) ,AMERICAN EXPRESS INTERNATIONAL BANKING CORPORATION v. CIT [2002] 258 ITR 601 (Bom) and CIT v. LORD KRISHNA BANK LTD. [2014] 366 ITR 416 (Bom). The Hon'ble Court also considered the cases of CIT v. Bank of Rajasthan Ltd. [2009] 316 ITR 391 (Raj) (para 2)CIT v. Reliance Utilities and Power Ltd. [2009] 313 ITR 340 (Bom) (para 4) CIT v. Lord Krishna Bank Ltd. [2014] 366 ITR 416 (Bom) (para 7) East India Pharmaceutical Works Ltd. v. CIT [1997] 224 ITR 627 (SC) (para 4)Southern Technologies Ltd. v. Joint CIT [2010] 320 ITR 577 (SC) (para 2)Vijaya Bank Ltd. v. Addl. CIT [1991] 187…

Sharekhan Ltd, Mumbai vs. DCIT CC 3(3), Mumbai

ITA 469/MUM/2017[2013-14]Status: DisposedITAT Mumbai03 Jul 2018AY 2013-14

Bench: Shri Joginder Singh & Shri N.K. Pradhan

Section 14ASection 36(1)(iii)

…TD. [2009] 313 ITR 340 (Bom) ,AMERICAN EXPRESS INTERNATIONAL BANKING CORPORATION v. CIT [2002] 258 ITR 601 (Bom) and CIT v. LORD KRISHNA BANK LTD. [2014] 366 ITR 416 (Bom). The Hon'ble Court also considered the cases of CIT v. Bank of Rajasthan Ltd. [2009] 316 ITR 391 (Raj) (para 2)CIT v. Reliance Utilities and Power Ltd. [2009] 313 ITR 340 (Bom) (para 4) CIT v. Lord Krishna Bank Ltd. [2014] 366 ITR 416 (Bom) (para 7) East India Pharmaceutical Works Ltd. v. CIT [1997] 224 ITR 627 (SC) (para 4)Southern Technologies Ltd. v. Joint CIT [2010] 320 ITR 577 (SC) (para 2)Vijaya Bank Ltd. v. Addl. CIT [1991] 187…

Sharekhan Ltd, Mumbai vs. ACIT CC 3(3), Mumbai

ITA 468/MUM/2017[2012-13]Status: DisposedITAT Mumbai03 Jul 2018AY 2012-13

Bench: Shri Joginder Singh & Shri N.K. Pradhan

Section 14ASection 36(1)(iii)

…TD. [2009] 313 ITR 340 (Bom) ,AMERICAN EXPRESS INTERNATIONAL BANKING CORPORATION v. CIT [2002] 258 ITR 601 (Bom) and CIT v. LORD KRISHNA BANK LTD. [2014] 366 ITR 416 (Bom). The Hon'ble Court also considered the cases of CIT v. Bank of Rajasthan Ltd. [2009] 316 ITR 391 (Raj) (para 2)CIT v. Reliance Utilities and Power Ltd. [2009] 313 ITR 340 (Bom) (para 4) CIT v. Lord Krishna Bank Ltd. [2014] 366 ITR 416 (Bom) (para 7) East India Pharmaceutical Works Ltd. v. CIT [1997] 224 ITR 627 (SC) (para 4)Southern Technologies Ltd. v. Joint CIT [2010] 320 ITR 577 (SC) (para 2)Vijaya Bank Ltd. v. Addl. CIT [1991] 187…

DCIT 2(1)(1), Mumbai vs. Bank of Baroda, Mumbai

In the result, grounds of appeal raised by Revenue are dismissed

ITA 5604/MUM/2016[2009-10]Status: DisposedITAT Mumbai01 Mar 2018AY 2009-10

Bench: Shri B.R. Baskaran & Shri Pawan Singhita No.5604/Mum/2016 (Assessment Year- 2009-10) Dcit-2(1)(1) M/S Bank Of Baroda Room No. 561, 5Th Floor, C-26, ‘G’ Block, Baroda Aayakar Bhavan, M.K. Corporate Centre, Bandra Vs. Road, Kurla Complex, Bandra (E), Mumbai-400020 Mumbai-400051 Pan: Aaacb1534F (Appellant) (Respondent) Assessee By : Ms. S. Padmaja (Cit-Dr) Revenue By : Shri C. Naresh (Ar) Date Of Hearing : 01.03.2018 Date Of Pronouncement : 01.03.2018 Order Under Section 254(1) Of Income Tax Act Per Pawan Singh: 1. These Two Appeal By Revenue Under Section 253 Of Income Tax Act Are Directed Against The Order Of Ld. Commissioner Of Income-Tax (Appeals)-4, Mumbai, [For Short The Ld. Cit(A)] Dated 30.06.2016 & 22.11. 2011 For Assessment Year 2008-09 & 2009-10 Respectively. The Revenue In Both The Appeals Has Raised Identical Grounds Of Appeal; Hence Both The Appeals Were Heard Together & Are Decided By Common Order. For Appreciation Of Fact, We Are Discussing The Fact For Assessment Year 2008-09. Though The Revenue Has Raised Two Ground Of Appeal, However, As Per Our Considered View The Sole Ground Of Appeal Is Whether Ld. Cit(A) Erred In Deleting The Broken Period Interest Expenditure. 2. Brief Facts Of The Case Are That Assessee Is Banking Company. The Assessee Is Carrying Banking Business. The Assessment For The Assessment Year 2008-09 Was Completed On 30.12.2010 Under Ita No. 5604/Mum/2016- M/S Bank Of Baroda

For Appellant: Ms. S. Padmaja (CIT-DR)For Respondent: Shri C. Naresh (AR)
Section 143(3)Section 147Section 148Section 253Section 254(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL, BENCH “I”, MUMBAI BEFORE SHRI B.R. BASKARAN, ACCOUNTANT MEMBER AND SHRI PAWAN SINGH, JUDICIAL MEMBER ITA No.5604/Mum/2016 (Assessment Year- 2009-10) DCIT-2(1)(1) M/s Bank of Baroda Room No. 561, 5th Floor, C-26, ‘G’ Block, Baroda Aayakar Bhavan, M.K. Corporate Centre, Bandra Vs. Road, Kurla Complex, Bandra (E), Mumbai-400020 Mumbai-400051 PAN: AAACB1534F (Appellant) (Respondent) Assessee by : Ms. S. Padmaja (CIT-DR) Revenue by : Shri C. Naresh (AR) Date of hearing : 01.03.2018 Date of Pronouncement : 01.03.2018 Order Under Section 254(1) of Income Tax Act PER PAWAN SI…

The Bharat Cooperative Bank (Mumbai) Ltd, Mumbai vs. DCIT (OSD) -1, Mumbai

In the result, appeal of the assessee is partly allowed, as above

ITA 3853/MUM/2016[2008-09]Status: DisposedITAT Mumbai19 Jan 2018AY 2008-09

Bench: Shri G.S. Pannu & Shri Ram Lal Negi: A.Y : 2008-09

For Appellant: Shri Bhupendra ShahFor Respondent: Shri Rajesh Kumar Yadav
Section 143(3)Section 147Section 148Section 234BSection 271(1)(c)Section 292B

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “A”, MUMBAI BEFORE SHRI G.S. PANNU, ACCOUNTANT MEMBER AND SHRI RAM LAL NEGI, JUDICIAL MEMBER : A.Y : 2008-09 The Bharat Cooperative Bank Vs. DCIT-1(3)(2), Mumbai (Mumbai) Ltd., (Respondent) 64/72, Mody Street, Fort, Mumbai 400 001 (Appellant) PAN : AAAAT0030E Appellant by : Shri Bhupendra Shah Respondent by : Shri Rajesh Kumar Yadav Date of Hearing : 26/10/2017 Date of Pronouncement : 19/01/2018 O R D E R PER G.S. PANNU, AM : The captioned appeal by the assessee is directed against the order of CIT(A)-2, Mumbai dated 18.04.2016, pertaining to the Assessment…

The Karnataka Bank Ltd., Mangalore vs. DCIT, Mangalore

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

ITA 1335/BANG/2013[2011-12]Status: DisposedITAT Bangalore19 Jan 2018AY 2011-12

Bench: Shri Inturi Rama Rao & Shri Lalit Kumar

For Appellant: Shri A. Raghavendra Rao, CAFor Respondent: Shri R.K.Jha, CIT(DR)
Section 143(3)

…rused the material on record. This issue is no longer res integra as the jurisdictional High Court in the ITA 147/08 dated 12/9/2012 in the assessee’s own case, following the decision of Hon’ble Bombay High Court in the case of CIT vs. Bank of Rajasthan Ltd. (326 ITR 526)(Bom) held as under: “16. It is declared u/s 5 of the Act that when interest is accrued or deemed to have been accrued, it is liable to tax. The word ‘accrued’ has defined the legal connotation. The interest that becomes due or liable to be payable whether or not it is paid, the interest is accrued or deemed to have been accrued. If the interest…

ACIT, Mangalore vs. M/S Karnataka Bank Ltd., Mangalore

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

ITA 1265/BANG/2013[2011-12]Status: DisposedITAT Bangalore19 Jan 2018AY 2011-12

Bench: Shri Inturi Rama Rao & Shri Lalit Kumar

For Appellant: Shri A. Raghavendra Rao, CAFor Respondent: Shri R.K.Jha, CIT(DR)
Section 143(3)

…rused the material on record. This issue is no longer res integra as the jurisdictional High Court in the ITA 147/08 dated 12/9/2012 in the assessee’s own case, following the decision of Hon’ble Bombay High Court in the case of CIT vs. Bank of Rajasthan Ltd. (326 ITR 526)(Bom) held as under: “16. It is declared u/s 5 of the Act that when interest is accrued or deemed to have been accrued, it is liable to tax. The word ‘accrued’ has defined the legal connotation. The interest that becomes due or liable to be payable whether or not it is paid, the interest is accrued or deemed to have been accrued. If the interest…

ACIT, Mangalore vs. M/S Karnataka Bank Ltd., Mangalore

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

ITA 1397/BANG/2012[2010-11]Status: DisposedITAT Bangalore19 Jan 2018AY 2010-11

Bench: Shri Inturi Rama Rao & Shri Lalit Kumar

For Appellant: Shri A. Raghavendra Rao, CAFor Respondent: Shri R.K.Jha, CIT(DR)
Section 143(3)

…rused the material on record. This issue is no longer res integra as the jurisdictional High Court in the ITA 147/08 dated 12/9/2012 in the assessee’s own case, following the decision of Hon’ble Bombay High Court in the case of CIT vs. Bank of Rajasthan Ltd. (326 ITR 526)(Bom) held as under: “16. It is declared u/s 5 of the Act that when interest is accrued or deemed to have been accrued, it is liable to tax. The word ‘accrued’ has defined the legal connotation. The interest that becomes due or liable to be payable whether or not it is paid, the interest is accrued or deemed to have been accrued. If the interest…

ACIT, Mangalore vs. M/S Karnataka Bank Ltd., Mangalore

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

ITA 1396/BANG/2012[2009-10]Status: DisposedITAT Bangalore19 Jan 2018AY 2009-10

Bench: Shri Inturi Rama Rao & Shri Lalit Kumar

For Appellant: Shri A. Raghavendra Rao, CAFor Respondent: Shri R.K.Jha, CIT(DR)
Section 143(3)

…rused the material on record. This issue is no longer res integra as the jurisdictional High Court in the ITA 147/08 dated 12/9/2012 in the assessee’s own case, following the decision of Hon’ble Bombay High Court in the case of CIT vs. Bank of Rajasthan Ltd. (326 ITR 526)(Bom) held as under: “16. It is declared u/s 5 of the Act that when interest is accrued or deemed to have been accrued, it is liable to tax. The word ‘accrued’ has defined the legal connotation. The interest that becomes due or liable to be payable whether or not it is paid, the interest is accrued or deemed to have been accrued. If the interest…

The Karnataka Bank Ltd., Mangalore vs. DCIT, Bangalore

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

ITA 1335/BANG/2012[2010-11]Status: DisposedITAT Bangalore19 Jan 2018AY 2010-11

Bench: Shri Inturi Rama Rao & Shri Lalit Kumar

For Appellant: Shri A. Raghavendra Rao, CAFor Respondent: Shri R.K.Jha, CIT(DR)
Section 143(3)

…rused the material on record. This issue is no longer res integra as the jurisdictional High Court in the ITA 147/08 dated 12/9/2012 in the assessee’s own case, following the decision of Hon’ble Bombay High Court in the case of CIT vs. Bank of Rajasthan Ltd. (326 ITR 526)(Bom) held as under: “16. It is declared u/s 5 of the Act that when interest is accrued or deemed to have been accrued, it is liable to tax. The word ‘accrued’ has defined the legal connotation. The interest that becomes due or liable to be payable whether or not it is paid, the interest is accrued or deemed to have been accrued. If the interest…

The Karnataka Bank Ltd., Mangalore vs. DCIT, Bangalore

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

ITA 1334/BANG/2012[2009-10]Status: DisposedITAT Bangalore19 Jan 2018AY 2009-10

Bench: Shri Inturi Rama Rao & Shri Lalit Kumar

For Appellant: Shri A. Raghavendra Rao, CAFor Respondent: Shri R.K.Jha, CIT(DR)
Section 143(3)

…rused the material on record. This issue is no longer res integra as the jurisdictional High Court in the ITA 147/08 dated 12/9/2012 in the assessee’s own case, following the decision of Hon’ble Bombay High Court in the case of CIT vs. Bank of Rajasthan Ltd. (326 ITR 526)(Bom) held as under: “16. It is declared u/s 5 of the Act that when interest is accrued or deemed to have been accrued, it is liable to tax. The word ‘accrued’ has defined the legal connotation. The interest that becomes due or liable to be payable whether or not it is paid, the interest is accrued or deemed to have been accrued. If the interest…