CIT v. ING Vysya Bank Limited

422 ITR 116High Court2020#3522 most cited

What is CIT v. ING Vysya Bank Limited authority for?

Section 115JB of the Income Tax Act does not apply to banking companies due to unworkable machinery provisions, and amortization of investments under the HTM category as per RBI guidelines is allowable expenditure under Section 37(1).

34

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2013 to 2026.

Also referred to as

CIT v. ING Vysya Bank Limited · section 115JB · banking company · MAT · RBI guidelines · amortization of investment · HTM category · section 37(1) · allowable expenditure

Also reported as

24 Taxmann.com 51
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Judgments citing CIT v. ING Vysya Bank Limited

Pr. Commissioner of Income Tax vs. M/S Syndicate Bank

The appeal stands dismissed

ITA/6/2025HC Karnataka05 Feb 2026

Bench: S.G.PANDIT,K. V. ARAVIND

Section 115JSection 2Section 260Section 260A

…ned counsel appearing for the respondent–assessee, submits that the issue relating to the applicability of Section 115JB of the Act to banking companies stands answered by this Court in Commissioner of Income Tax, Bangalore v. ING Vysya Bank Ltd. [(2020) 422 ITR 116 (Karnataka), dt. 16.01.2020]. It is submitted that this Court has held that the provisions of Section 115JB of the Act are not applicable to banking companies. 7. Sri Sushal Tiwari, learned Senior Standing Counsel appearing for the appellants–Revenue, submits that the aforesaid judgment of this Court has not been accepted by the…

Pr. Commissioner of Income Tax -7, Delhi vs. Punjab National Bank

ITA/193/2024HC Delhi06 Dec 2024

Bench: HON'BLE MR. JUSTICE TUSHAR RAO GEDELA,HON'BLE THE ACTING CHIEF JUSTICE

Section 143(3)Section 14ASection 260ASection 36(1)(viii)Section 43B

…Income Tax [2010] 320 ITR 577 (SC). 4. However, Mr. Shivpuri, learned Senior standing counsel appearing for the Revenue, seeks to place reliance on another decision of High Court of Karnataka in Commissioner of Income Tax v. ING VYSYA Bank Ltd. [2013] 356 ITR 532 (Kar.) where, in the facts of that case it was held that where the Assessee invested in securities for the purpose of complying with RBI instructions, such investments could not be termed as investment in the form of security ready for sale. 5. The Court is not persuaded to concur with the view expressed in ING VYSYA Bank Ltd. (supra) whic…

Assistant Commissioner of Income Tax, Circle - 7(1), Kolkata vs. Damodar Valley Corporation, Kolkata

ITA 892/KOL/2023[2018-2019]Status: DisposedITAT Kolkata30 Nov 2023AY 2018-2019

Bench: Sri Sanjay Garg & Dr. Manish Borad

Section 115JSection 143(2)Section 211Section 250

…lant therein while making the assessment of the tax payable under the Income-tax Act. On this issue, it would be beneficial to refer to the decision of the Hon'ble High Court of Karnataka in CIT v. ING Vysya Bank Ltd. [2020] 114 taxmann.com 506/270 Taxman 162/422 ITR 116. In the said decision it was held that provision of section 115JB cannot be made applicable to insurance companies, banking companies or companies engaged in generation or supply of electricity. The operative portion of the decision is as follows: "8. From close scrutiny of section 115JB(2) of the Act, it is axiomatic that every assessee being a…

Assistant Commissioner of Income Tax, Circle - 7(1), Kolkata vs. Damodar Valley Corporation, Kolkata

ITA 891/KOL/2023[2017-2018]Status: DisposedITAT Kolkata30 Nov 2023AY 2017-2018

Bench: Sri Sanjay Garg & Dr. Manish Borad

Section 115JSection 143(2)Section 211Section 250

…lant therein while making the assessment of the tax payable under the Income-tax Act. On this issue, it would be beneficial to refer to the decision of the Hon'ble High Court of Karnataka in CIT v. ING Vysya Bank Ltd. [2020] 114 taxmann.com 506/270 Taxman 162/422 ITR 116. In the said decision it was held that provision of section 115JB cannot be made applicable to insurance companies, banking companies or companies engaged in generation or supply of electricity. The operative portion of the decision is as follows: "8. From close scrutiny of section 115JB(2) of the Act, it is axiomatic that every assessee being a…

Assistant Commissioner of Income Tax, Circle - 7(1), Kolka, Kolkata vs. Damodar Valley Corporation, Kolkata

ITA 890/KOL/2023[2016-2017]Status: DisposedITAT Kolkata30 Nov 2023AY 2016-2017

Bench: Sri Sanjay Garg & Dr. Manish Borad

Section 115JSection 143(2)Section 211Section 250

…lant therein while making the assessment of the tax payable under the Income-tax Act. On this issue, it would be beneficial to refer to the decision of the Hon'ble High Court of Karnataka in CIT v. ING Vysya Bank Ltd. [2020] 114 taxmann.com 506/270 Taxman 162/422 ITR 116. In the said decision it was held that provision of section 115JB cannot be made applicable to insurance companies, banking companies or companies engaged in generation or supply of electricity. The operative portion of the decision is as follows: "8. From close scrutiny of section 115JB(2) of the Act, it is axiomatic that every assessee being a…

Assistant Commissioner of Income, Circle - 7(1), Kolkata vs. Damodar Valley Corporation, Kolkata

ITA 889/KOL/2023[2012-2013]Status: DisposedITAT Kolkata30 Nov 2023AY 2012-2013

Bench: Sri Sanjay Garg & Dr. Manish Borad

Section 115JSection 143(2)Section 211Section 250

…lant therein while making the assessment of the tax payable under the Income-tax Act. On this issue, it would be beneficial to refer to the decision of the Hon'ble High Court of Karnataka in CIT v. ING Vysya Bank Ltd. [2020] 114 taxmann.com 506/270 Taxman 162/422 ITR 116. In the said decision it was held that provision of section 115JB cannot be made applicable to insurance companies, banking companies or companies engaged in generation or supply of electricity. The operative portion of the decision is as follows: "8. From close scrutiny of section 115JB(2) of the Act, it is axiomatic that every assessee being a…

M/S. Canara Bank (Erstwhile Syndicate Bank), Bangalore vs. The Deputy Commissioner of Income Tax, Circle-2(1)(1), Bangalore

ITA 389/BANG/2023[2015-16]Status: DisposedITAT Bangalore26 Sept 2023AY 2015-16

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

For Appellant: Shri S. Ananthan, CAFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bengaluru
Section 115JSection 147Section 250Section 36(1)(viia)Section 5

…t by applying this principle, held that the provisions of section 115JB are not applicable. This decision is reported in [2019] 13 ITR-OL 655 (Bom). This decision was followed by the Hon’ble Karnataka High Court in the case of CIT vs ING Vysya Bank Ltd [2020] 422 ITR 116 (Kar.). The Hon’ble Bombay High Court held in para 11 as under: “11. This legal dichotomy emerging from the provisions of sub- section (2) of section 115JB particularly having regard to the first proviso contained therein in the case of a banking company, would convince us that machinery provision provided in sub- section (2) of section 115JB of…

M/S. Canara Bank (Erstwhile Syndicate Bank), Bangalore vs. The Deputy Commissioner of Income Tax, Circle-2(1)(1), Bangalore

ITA 388/BANG/2023[2014-15]Status: DisposedITAT Bangalore26 Sept 2023AY 2014-15

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

For Appellant: Shri S. Ananthan, CAFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bengaluru
Section 115JSection 147Section 250Section 36(1)(viia)Section 5

…t by applying this principle, held that the provisions of section 115JB are not applicable. This decision is reported in [2019] 13 ITR-OL 655 (Bom). This decision was followed by the Hon’ble Karnataka High Court in the case of CIT vs ING Vysya Bank Ltd [2020] 422 ITR 116 (Kar.). The Hon’ble Bombay High Court held in para 11 as under: “11. This legal dichotomy emerging from the provisions of sub- section (2) of section 115JB particularly having regard to the first proviso contained therein in the case of a banking company, would convince us that machinery provision provided in sub- section (2) of section 115JB of…

M/S. Canara Bank (Erstwhile Syndicate Bank), Bangalore vs. Deputy Commissioner of Income-Tax, Ltu, Circle-2, Bangalore

In the result, the appeals are partly allowed for statistical purposes

ITA 229/BANG/2023[2013-14]Status: DisposedITAT Bangalore28 Apr 2023AY 2013-14

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

For Appellant: Shri Ananthan S. & Smt. Lalitha R., AdvocatesFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bengaluru
Section 115JSection 143(1)Section 143(3)Section 147Section 148Section 36(1)(vii)

…ll corresponding new banks. 35. Before the CIT(Appeals), the assessee filed written submissions and contended that the provisions of section 115JB are not applicable to banking companies and relied on the following case laws:- 1. ING Vysya Bank Ltd. (2020) (422 ITR 116) (Karnataka) 2. Union Bank of India (2019) (13 ITR —OL 655) (Bombay) 3. Syndicate Bank (ITA No 99 & 100/PAN/2017 dated 23.01.2020) 36. The assessee also submitted that various additions made by the AO while computing book profit under section 115JB are not covered by the Explanation 2 to section 115JB and therefore these additions are not tenable…

M/S. Canara Bank (Erstwhile Syndicate Bank), Bangalore vs. Assistant Commissioner of Income-Tax, Circle-2(1)(1), Bangalore

In the result, the appeals are partly allowed for statistical purposes

ITA 228/BANG/2023[2012-13]Status: DisposedITAT Bangalore28 Apr 2023AY 2012-13

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

For Appellant: Shri Ananthan S. & Smt. Lalitha R., AdvocatesFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bengaluru
Section 115JSection 143(1)Section 143(3)Section 147Section 148Section 36(1)(vii)

…ll corresponding new banks. 35. Before the CIT(Appeals), the assessee filed written submissions and contended that the provisions of section 115JB are not applicable to banking companies and relied on the following case laws:- 1. ING Vysya Bank Ltd. (2020) (422 ITR 116) (Karnataka) 2. Union Bank of India (2019) (13 ITR —OL 655) (Bombay) 3. Syndicate Bank (ITA No 99 & 100/PAN/2017 dated 23.01.2020) 36. The assessee also submitted that various additions made by the AO while computing book profit under section 115JB are not covered by the Explanation 2 to section 115JB and therefore these additions are not tenable…

M/S. Canara Bank (Erstwhile Syndicate Bank), Bangalore vs. Assistant Commissioner of Income-Tax, Circle-2(1)(1), Bangalore

In the result, the appeals are partly allowed for statistical purposes

ITA 227/BANG/2023[2011-12]Status: DisposedITAT Bangalore28 Apr 2023AY 2011-12

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

For Appellant: Shri Ananthan S. & Smt. Lalitha R., AdvocatesFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bengaluru
Section 115JSection 143(1)Section 143(3)Section 147Section 148Section 36(1)(vii)

…ll corresponding new banks. 35. Before the CIT(Appeals), the assessee filed written submissions and contended that the provisions of section 115JB are not applicable to banking companies and relied on the following case laws:- 1. ING Vysya Bank Ltd. (2020) (422 ITR 116) (Karnataka) 2. Union Bank of India (2019) (13 ITR —OL 655) (Bombay) 3. Syndicate Bank (ITA No 99 & 100/PAN/2017 dated 23.01.2020) 36. The assessee also submitted that various additions made by the AO while computing book profit under section 115JB are not covered by the Explanation 2 to section 115JB and therefore these additions are not tenable…

Oriental Bank of Commerce, Gurgaon vs. ACIT, Spl. Range-07, New Delhi

In the result, the appeal filed by the Assessee stands allowed

ITA 740/DEL/2020[2016-17]Status: DisposedITAT Delhi31 Mar 2023AY 2016-17

Bench: Shri Anil Chaturvedi & Shri N.K. Choudhryassessment Year: 2016-17

For Appellant: Sh. KVSR Krishna, Ld. CA &For Respondent: Ms. Sarita Kumar, Ld. CIT/DR
Section 115JSection 14ASection 250Section 36

…t the Revenue and confirm the order of the Commissioner of Income- tax (Appeals) on this issue.” 23. The above judgment of the Hon’ble Bombay High Court has been followed by the Hon’ble Karnataka High Court in the case of CIT vs. ING Vysya Bank Limited (2020) 422 ITR 116. The Hon’ble Karnataka High Court decided on two issues— one was whether the provision of section 115JB of the Income Tax Act would apply to a banking company and the second was whether the amortization of investment under HTM category done as per RBI guidelines was allowable expenditure u/s 37(1) of the Act. 24. At page 20 of the paper book is t…

Assistant Commissioner of Income-Tax, Circle - 6, Pune vs. M/S. Janata Sahakari Bank Ltd, Pune

In the result, the appeal filed by the Revenue in ITA

ITA 2428/PUN/2017[2013-14]Status: DisposedITAT Pune10 May 2022AY 2013-14

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

For Appellant: Shri Nikhil PathakFor Respondent: Shri J. P. Chadraker
Section 143(3)

…ose of Income-tax proceedings, the investments were treated as stock-in-trade. Thus, grounds of Appeal Nos. 4, 5 and 6 are disposed of." hon'ble jurisdictional High Court in the case of CIT v. ING Vysya Bank Ltd. [2012] 24 taxmann.com 51/208 Taxman 511/[2013] 356 ITR 532 (Kar.) is misplaced for the reason that hon'ble jurisdictional High Court in the case of Karnataka Bank (supra) held that the decision in ING Vysya Bank (supra) runs counter to law lay down by the hon'ble apex court in the case of UCO Bank (supra). In the light of the above position in law, we direct the Assessing Officer to allow fall in value o…

Janata Sahakari Bank Limited, Pune vs. Deputy Commissioner of Income-Tax, Circle - 6, Pune

In the result, the appeal filed by the Revenue in ITA

ITA 2400/PUN/2017[2013-14]Status: DisposedITAT Pune10 May 2022AY 2013-14

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

For Appellant: Shri Nikhil PathakFor Respondent: Shri J. P. Chadraker
Section 143(3)

…ose of Income-tax proceedings, the investments were treated as stock-in-trade. Thus, grounds of Appeal Nos. 4, 5 and 6 are disposed of." hon'ble jurisdictional High Court in the case of CIT v. ING Vysya Bank Ltd. [2012] 24 taxmann.com 51/208 Taxman 511/[2013] 356 ITR 532 (Kar.) is misplaced for the reason that hon'ble jurisdictional High Court in the case of Karnataka Bank (supra) held that the decision in ING Vysya Bank (supra) runs counter to law lay down by the hon'ble apex court in the case of UCO Bank (supra). In the light of the above position in law, we direct the Assessing Officer to allow fall in value o…

Janata Sahakari Bank Ltd, Pune vs. Deputy Commissioner of Income-Tax, Circle - 6, Pune

In the result, the appeal filed by the Revenue in ITA

ITA 2641/PUN/2017[2014-15]Status: DisposedITAT Pune10 May 2022AY 2014-15

Bench: Shri Inturi Rama Rao & Shri S. S. Viswanethra Ravisl.

For Appellant: Shri Nikhil PathakFor Respondent: Shri J. P. Chadraker
Section 143(3)

…ose of Income-tax proceedings, the investments were treated as stock-in-trade. Thus, grounds of Appeal Nos. 4, 5 and 6 are disposed of." hon'ble jurisdictional High Court in the case of CIT v. ING Vysya Bank Ltd. [2012] 24 taxmann.com 51/208 Taxman 511/[2013] 356 ITR 532 (Kar.) is misplaced for the reason that hon'ble jurisdictional High Court in the case of Karnataka Bank (supra) held that the decision in ING Vysya Bank (supra) runs counter to law lay down by the hon'ble apex court in the case of UCO Bank (supra). In the light of the above position in law, we direct the Assessing Officer to allow fall in value o…

ACIT, Circle- 19(1), New Delhi vs. Oriental Bank of Commerce, Gurgaon

In the result, the appeals of the assessee are allowed and the appeals of the Revenue are dismissed

ITA 1812/DEL/2018[2015-16]Status: DisposedITAT Delhi04 Mar 2022AY 2015-16

Bench: Sh. A. D. Jain, Vice-Dr. B. R. R. Kumarita No. 1581/Del/2017 : Asstt. Year : 2012-13 Ita No. 1582/Del/2017 : Asstt. Year : 2013-14 Ita No. 1583/Del/2017 : Asstt. Year : 2014-15 Ita No. 1199/Del/2018 : Asstt. Year : 2015-16 Oriental Bank Of Commerce, Vs Addl. Cit, Central Accounts Office, Plot No. 5, Range-13 (Present Range-19) Sector-32, Institutional Area, New Delhi Gurgaon-122001 Dcit/Acit, Circle-19(1), New Delhi (Appellant) (Respondent) Pan No. Aaaco0191M

For Appellant: Sh. KVSR Krishna, CAFor Respondent: Ms. Sarita Kumari, CIT DR
Section 14A

…issue.” ITA No.1581 & Ors./Del/2017 10 ITA No. 1199 & Ors./Del/2018 Oriental Bank of Commerce 23. The above judgment of the Hon’ble Bombay High Court has been followed by the Hon’ble Karnataka High Court in the case of CIT vs. ING Vysya Bank Limited (2020) 422 ITR 116. The Hon’ble Karnataka High Court decided on two issues— one was whether the provision of section 115JB of the Income Tax Act would apply to a banking company and the second was whether the amortization of investment under HTM category done as per RBI guidelines was allowable expenditure u/s 37(1) of the Act. 24. At page 20 of the paper book is…

Oriental Bank of Commerce, Gurgaon vs. ACIT, Circle- 19(1), New Delhi

In the result, the appeals of the assessee are allowed and the appeals of the Revenue are dismissed

ITA 1199/DEL/2018[2015-16]Status: DisposedITAT Delhi04 Mar 2022AY 2015-16

Bench: Sh. A. D. Jain, Vice-Dr. B. R. R. Kumarita No. 1581/Del/2017 : Asstt. Year : 2012-13 Ita No. 1582/Del/2017 : Asstt. Year : 2013-14 Ita No. 1583/Del/2017 : Asstt. Year : 2014-15 Ita No. 1199/Del/2018 : Asstt. Year : 2015-16 Oriental Bank Of Commerce, Vs Addl. Cit, Central Accounts Office, Plot No. 5, Range-13 (Present Range-19) Sector-32, Institutional Area, New Delhi Gurgaon-122001 Dcit/Acit, Circle-19(1), New Delhi (Appellant) (Respondent) Pan No. Aaaco0191M

For Appellant: Sh. KVSR Krishna, CAFor Respondent: Ms. Sarita Kumari, CIT DR
Section 14A

…issue.” ITA No.1581 & Ors./Del/2017 10 ITA No. 1199 & Ors./Del/2018 Oriental Bank of Commerce 23. The above judgment of the Hon’ble Bombay High Court has been followed by the Hon’ble Karnataka High Court in the case of CIT vs. ING Vysya Bank Limited (2020) 422 ITR 116. The Hon’ble Karnataka High Court decided on two issues— one was whether the provision of section 115JB of the Income Tax Act would apply to a banking company and the second was whether the amortization of investment under HTM category done as per RBI guidelines was allowable expenditure u/s 37(1) of the Act. 24. At page 20 of the paper book is…

ACIT, New Delhi vs. M/S. Oriental Bank of Commerce, Gurgaon

In the result, the appeals of the assessee are allowed and the appeals of the Revenue are dismissed

ITA 2174/DEL/2017[2014-15]Status: DisposedITAT Delhi04 Mar 2022AY 2014-15

Bench: Sh. A. D. Jain, Vice-Dr. B. R. R. Kumarita No. 1581/Del/2017 : Asstt. Year : 2012-13 Ita No. 1582/Del/2017 : Asstt. Year : 2013-14 Ita No. 1583/Del/2017 : Asstt. Year : 2014-15 Ita No. 1199/Del/2018 : Asstt. Year : 2015-16 Oriental Bank Of Commerce, Vs Addl. Cit, Central Accounts Office, Plot No. 5, Range-13 (Present Range-19) Sector-32, Institutional Area, New Delhi Gurgaon-122001 Dcit/Acit, Circle-19(1), New Delhi (Appellant) (Respondent) Pan No. Aaaco0191M

For Appellant: Sh. KVSR Krishna, CAFor Respondent: Ms. Sarita Kumari, CIT DR
Section 14A

…issue.” ITA No.1581 & Ors./Del/2017 10 ITA No. 1199 & Ors./Del/2018 Oriental Bank of Commerce 23. The above judgment of the Hon’ble Bombay High Court has been followed by the Hon’ble Karnataka High Court in the case of CIT vs. ING Vysya Bank Limited (2020) 422 ITR 116. The Hon’ble Karnataka High Court decided on two issues— one was whether the provision of section 115JB of the Income Tax Act would apply to a banking company and the second was whether the amortization of investment under HTM category done as per RBI guidelines was allowable expenditure u/s 37(1) of the Act. 24. At page 20 of the paper book is…

ACIT, New Delhi vs. M/S. Oriental Bank of Commerce, Gurgaon

In the result, the appeals of the assessee are allowed and the appeals of the Revenue are dismissed

ITA 2173/DEL/2017[2013-14]Status: DisposedITAT Delhi04 Mar 2022AY 2013-14

Bench: Sh. A. D. Jain, Vice-Dr. B. R. R. Kumarita No. 1581/Del/2017 : Asstt. Year : 2012-13 Ita No. 1582/Del/2017 : Asstt. Year : 2013-14 Ita No. 1583/Del/2017 : Asstt. Year : 2014-15 Ita No. 1199/Del/2018 : Asstt. Year : 2015-16 Oriental Bank Of Commerce, Vs Addl. Cit, Central Accounts Office, Plot No. 5, Range-13 (Present Range-19) Sector-32, Institutional Area, New Delhi Gurgaon-122001 Dcit/Acit, Circle-19(1), New Delhi (Appellant) (Respondent) Pan No. Aaaco0191M

For Appellant: Sh. KVSR Krishna, CAFor Respondent: Ms. Sarita Kumari, CIT DR
Section 14A

…issue.” ITA No.1581 & Ors./Del/2017 10 ITA No. 1199 & Ors./Del/2018 Oriental Bank of Commerce 23. The above judgment of the Hon’ble Bombay High Court has been followed by the Hon’ble Karnataka High Court in the case of CIT vs. ING Vysya Bank Limited (2020) 422 ITR 116. The Hon’ble Karnataka High Court decided on two issues— one was whether the provision of section 115JB of the Income Tax Act would apply to a banking company and the second was whether the amortization of investment under HTM category done as per RBI guidelines was allowable expenditure u/s 37(1) of the Act. 24. At page 20 of the paper book is…

Oriental Bank of Commerce, Gurgaon vs. DCIT, New Delhi

In the result, the appeals of the assessee are allowed and the appeals of the Revenue are dismissed

ITA 1583/DEL/2017[2014-15]Status: DisposedITAT Delhi04 Mar 2022AY 2014-15

Bench: Sh. A. D. Jain, Vice-Dr. B. R. R. Kumarita No. 1581/Del/2017 : Asstt. Year : 2012-13 Ita No. 1582/Del/2017 : Asstt. Year : 2013-14 Ita No. 1583/Del/2017 : Asstt. Year : 2014-15 Ita No. 1199/Del/2018 : Asstt. Year : 2015-16 Oriental Bank Of Commerce, Vs Addl. Cit, Central Accounts Office, Plot No. 5, Range-13 (Present Range-19) Sector-32, Institutional Area, New Delhi Gurgaon-122001 Dcit/Acit, Circle-19(1), New Delhi (Appellant) (Respondent) Pan No. Aaaco0191M

For Appellant: Sh. KVSR Krishna, CAFor Respondent: Ms. Sarita Kumari, CIT DR
Section 14A

…issue.” ITA No.1581 & Ors./Del/2017 10 ITA No. 1199 & Ors./Del/2018 Oriental Bank of Commerce 23. The above judgment of the Hon’ble Bombay High Court has been followed by the Hon’ble Karnataka High Court in the case of CIT vs. ING Vysya Bank Limited (2020) 422 ITR 116. The Hon’ble Karnataka High Court decided on two issues— one was whether the provision of section 115JB of the Income Tax Act would apply to a banking company and the second was whether the amortization of investment under HTM category done as per RBI guidelines was allowable expenditure u/s 37(1) of the Act. 24. At page 20 of the paper book is…