What is CIT v. Syndicate Bank authority for?

The deduction under Section 36(1)(viia) for provisions for bad and doubtful debts is allowed to the extent of the actual provision made, subject to the prescribed ceiling. If the provision made is less than the prescribed limit, the deduction is limited to the actual provision made.

How many judgments cite CIT v. Syndicate Bank?

28 judgments on BharatTax cite CIT v. Syndicate Bank (422 ITR 460), spanning 2015 to 2026.

Which sections of the Income Tax Act does CIT v. Syndicate Bank come up under?

It is most often cited in judgments turning on Section 14A, Section 36(1)(viia), Section 143(3), Section 148, Section 115JB, Section 36(1)(vii).

CIT v. Syndicate Bank (422 ITR 460)

DEPUTY COMMISSIONER INCOME TAX NON CORP CIRCLE II MADURAI, MADURAI vs. VIRUDHUNAGAR DISTRICT CENTRAL CO OP BANK LIMITED, VIRUDHUNAGAR

ITA 2700/CHNY/2025[2015-16]Status: DisposedITAT Chennai28 Jan 2026AY 2015-16

Section 14ASection 36(1)(viia)

…se laws relied on by the assessee has been distinguished by the CIT(A) in the impugned orders at page 39 to 44 and we approve the CIT(A) order in distinguishing the same. The Hon'ble Karnataka High Court in the case of CIT Vs Syndicate Bank reported in (2020) 422 ITR 460 (Kar) considered an identical issue and has categorically held that conditions precedent for claiming deduction u/s.36(1)(viia) of the Act is that there should have been “provision" made and if the “provision” so made is excess of prescribed limit made u/s., then deduction will be allowed only to the extent of limit so prescribed. However, if the…

DEPUTY COMMISSIONER OF INCOME TAX NON CORP CIRCLE II MADURAI, MADURAI vs. VIRUDHUNAGAR DISTRICT CENTRAL CO OP BANK LIMITED, VIRUDHUNAGAR

ITA 2699/CHNY/2025[2013-14]Status: DisposedITAT Chennai28 Jan 2026AY 2013-14

Bench: Ms. Padmavathy S & Shri Manu Kumar Giriआयकर अपीलसं/.Ita Nos.: 2699/Chny/2025 &2700/Chny/2025 By Revenue C.O.No.92/Chny/2025 (In Ita No.: 2699/Chny/2025)& C.O.No.93/Chny/2025 (In Ita No.: 2700/Chny/2025) By Assessee निर्धारणवर्ष / Assessment Years: 2013-14 & 2015-16 Dcit, Non Corp Circle Ii, Madurai, V.P. Rathinasamy Nadar Road, Bb Kulam Madurai-625002, Madurai, Tamil Nadu (अपीलार्थी/Assessee) V. Virudhunagar District Central Co-Operative Bank Limited 104/1, Madurai Road, Kamaraj Nagar, S.O. Virudhunagar,Virudhunagar- 626001. Tamil Nadu [Pan:Aaaav 0147 N] (प्रत्यर्थी/Respondent) अपीलार्थीकीओरसे//Assessee By Mr. R. Prasanna Venkatesan, F.C.A. प्रत्यर्थीकी ओरसे Respondent/Revenue By Mr. Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing 20.01.2026 घोषणाकीतारीख /Date Of Pronouncement 28.01.2026 :-2-:

Section 14ASection 36(1)(viia)

…se laws relied on by the assessee has been distinguished by the CIT(A) in the impugned orders at page 39 to 44 and we approve the CIT(A) order in distinguishing the same. The Hon'ble Karnataka High Court in the case of CIT Vs Syndicate Bank reported in (2020) 422 ITR 460 (Kar) considered an identical issue and has categorically held that conditions precedent for claiming deduction u/s.36(1)(viia) of the Act is that there should have been “provision…

THE VIRUDHUNAGAR DIST CETNRAL CO- OPERATIVE BANK LIMITED,VIRUDHUNAGAR vs. DCIT,-DCAT, MADURAI-2,, VIRUDHUNAGAR

ITA 2790/CHNY/2024[2010-11]Status: DisposedITAT Chennai21 Mar 2025AY 2010-11

For Appellant: Shri Manoj Menon, AdvocateFor Respondent: Shri R.Clement Ramesh Kumar, CIT

Section 143(3)Section 148Section 250Section 36(1)(viia)

…amount of provisions debited to the profit & loss account as per RBI norms is no longer res integra, as the same is covered in favour of the Revenue by the judgements of the Hon'ble Karnataka High Court in the case of CIT Vs.Syndicate Bank reported in (2020) 422 ITR 460 (Kar), in the case of CIT Vijaya Bank in ITA No.1066 of 2008 (judgement dated 21.10.2024) and judgement of the Hon'ble Punjab & Haryana High Court in the case of State Bank of Patiala Vs.CIT reported in (2005) 272 ITR 54 (P&H). 9. We have heard rival submissions and perused material on record. As mentioned earlier, the solitary issue that has rai…

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-2(1)(1), BENGALURU, BENGALURU vs. CANARA BANK, BENGALURU

In the result, appeal of the revenue is partly allowed for statistical purposes

ITA 1102/BANG/2024[2014-15]Status: DisposedITAT Bangalore16 Oct 2024AY 2014-15

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessmentyear:2014-15

For Appellant: Shri S. Ananthan, A.R. &For Respondent: Sri Subramanian S., D.R

Section 115JSection 142(1)Section 211Section 211(2)Section 37Section 37(1)Section 5

…t is not for any contractual obligation. It is a violation of law. Hence, it is covered under explanation of section 37(1) of the Act and he relied on the following judgement of Hon’ble High Court of Karnataka in the case of CIT Vs. Syndicate Bank reported in 261 ITR 528 and decision of ITAT Bangalore in the case of Vijaya Bank in ITA Nos.578 & 653/Bang/2012 dated 27.2.2015 and accordingly, he disallowed and added back into the total income of the assessee and AO also made other additions. 2.1 Aggrieved from the above order of the AO, the assessee filed appeal before the first appellate authority Canara Bank, Ban…

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-2(1)(1), BENGALURU, BENGALURU vs. CANARA BANK, BENGALURU

In the result, revenue’s appeal in ITA No

ITA 716/BANG/2024[2015-16]Status: DisposedITAT Bangalore10 Jun 2024AY 2015-16

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment Year: 2015-16

For Appellant: Sri S. Ananthan, A.RFor Respondent: Ms. Neera Malhotra, D.R

Section 14Section 147Section 14ASection 154

…under the provisions of Banking Regulation Act, hence, any payment in violation of the RBI directions is not allowable as deduction u/s. 37(1) read with Explanation. He also relied on the judgment of Hon’ble Karnataka High Court in the case of Syndicate Bank 261 ITR 528 in which penalty has been confirmed for violation of section 24(4)(a) and 24(4)(b) of the Banking Regulation Act and the penalty paid by the assessee bank for violation of above section was not allowed. 35. The ld. AR reiterated the submissions made before the CIT(A) to which we have noted and he also relied on the judgment of the coordinate Ben…

CANARA BANK,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE, BENGALURU

In the result, revenue’s appeal in ITA No

ITA 111/BANG/2024[2015-16]Status: DisposedITAT Bangalore10 Jun 2024AY 2015-16

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment Year: 2015-16

For Appellant: Sri S. Ananthan, A.RFor Respondent: Ms. Neera Malhotra, D.R

Section 14Section 147Section 14ASection 154

…under the provisions of Banking Regulation Act, hence, any payment in violation of the RBI directions is not allowable as deduction u/s. 37(1) read with Explanation. He also relied on the judgment of Hon’ble Karnataka High Court in the case of Syndicate Bank 261 ITR 528 in which penalty has been confirmed for violation of section 24(4)(a) and 24(4)(b) of the Banking Regulation Act and the penalty paid by the assessee bank for violation of above section was not allowed. 35. The ld. AR reiterated the submissions made before the CIT(A) to which we have noted and he also relied on the judgment of the coordinate Ben…

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, CUDDALLORE vs. M/S VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD., VILLUPURAM

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

ITA 981/CHNY/2020[2008-09]Status: DisposedITAT Chennai18 Oct 2023AY 2008-09

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT

Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

…of the judgment of Hon’ble Punjab & Haryana High Court in the case of State Bank of Patiala directly applies to the current controversy raised by assessee. Even the recent decision of Hon’ble Karnataka High Court in the case of CIT vs. Syndicate Bank, [2020] 422 ITR 460 (Karn) has explained the provisions and held that the condition precedent for claiming deduction under section 36(1)(viia) is that a provision for bad and doubtful debts should be made in the accounts of the assessee. The language employed in the section is clear and ambiguous. In the absence of any provision, the assessee is not entitled to dedu…

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. ACIT, CIRCLE-I,, CUDDALORE

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

ITA 858/CHNY/2020[2009-10]Status: DisposedITAT Chennai18 Oct 2023AY 2009-10

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT

Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

…of the judgment of Hon’ble Punjab & Haryana High Court in the case of State Bank of Patiala directly applies to the current controversy raised by assessee. Even the recent decision of Hon’ble Karnataka High Court in the case of CIT vs. Syndicate Bank, [2020] 422 ITR 460 (Karn) has explained the provisions and held that the condition precedent for claiming deduction under section 36(1)(viia) is that a provision for bad and doubtful debts should be made in the accounts of the assessee. The language employed in the section is clear and ambiguous. In the absence of any provision, the assessee is not entitled to dedu…

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. ACIT, CIRCLE-II,, CUDDALORE

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

ITA 857/CHNY/2020[2008-09]Status: DisposedITAT Chennai18 Oct 2023AY 2008-09

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT

Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

…of the judgment of Hon’ble Punjab & Haryana High Court in the case of State Bank of Patiala directly applies to the current controversy raised by assessee. Even the recent decision of Hon’ble Karnataka High Court in the case of CIT vs. Syndicate Bank, [2020] 422 ITR 460 (Karn) has explained the provisions and held that the condition precedent for claiming deduction under section 36(1)(viia) is that a provision for bad and doubtful debts should be made in the accounts of the assessee. The language employed in the section is clear and ambiguous. In the absence of any provision, the assessee is not entitled to dedu…

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. DCIT, VILLUPURAM CIRCLE,, VILLUPRUAM

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

ITA 856/CHNY/2020[202-13]Status: DisposedITAT Chennai18 Oct 2023

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT

Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

…of the judgment of Hon’ble Punjab & Haryana High Court in the case of State Bank of Patiala directly applies to the current controversy raised by assessee. Even the recent decision of Hon’ble Karnataka High Court in the case of CIT vs. Syndicate Bank, [2020] 422 ITR 460 (Karn) has explained the provisions and held that the condition precedent for claiming deduction under section 36(1)(viia) is that a provision for bad and doubtful debts should be made in the accounts of the assessee. The language employed in the section is clear and ambiguous. In the absence of any provision, the assessee is not entitled to dedu…

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. DCIT, VILLUPURAM CIRCLE,, VILLUPURAM

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

ITA 855/CHNY/2020[2011-12]Status: DisposedITAT Chennai18 Oct 2023AY 2011-12

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT

Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

…of the judgment of Hon’ble Punjab & Haryana High Court in the case of State Bank of Patiala directly applies to the current controversy raised by assessee. Even the recent decision of Hon’ble Karnataka High Court in the case of CIT vs. Syndicate Bank, [2020] 422 ITR 460 (Karn) has explained the provisions and held that the condition precedent for claiming deduction under section 36(1)(viia) is that a provision for bad and doubtful debts should be made in the accounts of the assessee. The language employed in the section is clear and ambiguous. In the absence of any provision, the assessee is not entitled to dedu…

THE VILLUPURAM DISTRICT CENTRAL COOPERTATIVE BANK LTD.,,VILLUPURAM vs. DCIT, VILLUPURAM CIRCLE,, VILLUPURAM

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

ITA 854/CHNY/2020[2010-11]Status: DisposedITAT Chennai18 Oct 2023AY 2010-11

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT

Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

…of the judgment of Hon’ble Punjab & Haryana High Court in the case of State Bank of Patiala directly applies to the current controversy raised by assessee. Even the recent decision of Hon’ble Karnataka High Court in the case of CIT vs. Syndicate Bank, [2020] 422 ITR 460 (Karn) has explained the provisions and held that the condition precedent for claiming deduction under section 36(1)(viia) is that a provision for bad and doubtful debts should be made in the accounts of the assessee. The language employed in the section is clear and ambiguous. In the absence of any provision, the assessee is not entitled to dedu…

THE CUDDALORE DISTRICT CENTRAL CO-OP BANK LTD.,CUDDALORE vs. DCIT CUDDALORE CIRCLE, CUDDALORE

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

ITA 2645/CHNY/2019[2016-17]Status: DisposedITAT Chennai18 Oct 2023AY 2016-17

Bench: Shri Mahavir Singh & Shri Manjunatha.G

For Appellant: Shri K. Ravi, AdvocateFor Respondent: Shri N.B. Som, CIT

Section 143(1)Section 143(2)Section 143(3)Section 143(3)(ii)Section 147Section 148Section 36(1)(viia)

…of the judgment of Hon’ble Punjab & Haryana High Court in the case of State Bank of Patiala directly applies to the current controversy raised by assessee. Even the recent decision of Hon’ble Karnataka High Court in the case of CIT vs. Syndicate Bank, [2020] 422 ITR 460 (Karn) has explained the provisions and held that the condition precedent for claiming deduction under section 36(1)(viia) is that a provision for bad and doubtful debts should be made in the accounts of the assessee. The language employed in the section is clear and ambiguous. In the absence of any provision, the assessee is not entitled to dedu…

ADDL/JOINT COMMISSIONER OF INCOME TAX (LTU) , BANGALORE vs. M/S VIJAYA BANK , BANGALORE

Accordingly the grounds raised by the revenue is allowed for statistical purposes

ITA 528/BANG/2019[2015-16]Status: DisposedITAT Bangalore25 Apr 2023AY 2015-16

Bench: Shri George George K. & Shri Laxmi Prasad Sahum/S. Bank Of Baroda Vs. Addl. Cit, Ltu, (Erstwhile Vijaya Bank) Bmtc Building 7Th Floor, Central Accounts 6Th Block, Koramangala Bengaluru 560095 Dept., 41/2, M.G. Road Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Acit, Circle - 2(1)(1) Vs. M/S. Bank Of Baroda Room No. 561, 5Th Floor (Erstwhile Vijaya Bank) Aayakar Bhavan 7Th Floor, Central Accounts M.K. Road Dept., 41/2, M.G. Road Mumbai 400020 Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Assessee By: Shri Ananthan, Ca& Smt. Lalitha Rameswaran, Ca Revenue By: Shri G. Manoj Kumar, Cit-Dr Date Of Hearing: 29.03.2023 Date Of Pronouncement: 25.04.2023 M/S. Bank Of Baroda

For Appellant: Shri Ananthan, CA&For Respondent: Shri G. Manoj Kumar, CIT-DR

Section 115JSection 14ASection 194JSection 36Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

…of Baroda provisions of Banking Regulation Act, hence, any payment in violation of the RBI directions is not allowable as deduction u/s. 37(1) read with Explanation. He also relied on the judgment of Hon’ble Karnataka High Court in the case of Syndicate Bank 261 ITR 528 in which penalty has been confirmed for violation of section 24(4)(a) and 24(4)(b) of the Banking Regulation Act and the penalty paid by the assessee bank for violation of above section was not allowed. 35. The ld. AR reiterated the submissions made before the CIT(A) to which we have noted and he also relied on the judgment of the coordinate Ben…

M/S VIJAYA BANK ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX LTU , BANGALORE

Accordingly the grounds raised by the revenue is allowed for statistical purposes

ITA 321/BANG/2019[2015-16]Status: DisposedITAT Bangalore25 Apr 2023AY 2015-16

Bench: Shri George George K. & Shri Laxmi Prasad Sahum/S. Bank Of Baroda Vs. Addl. Cit, Ltu, (Erstwhile Vijaya Bank) Bmtc Building 7Th Floor, Central Accounts 6Th Block, Koramangala Bengaluru 560095 Dept., 41/2, M.G. Road Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Acit, Circle - 2(1)(1) Vs. M/S. Bank Of Baroda Room No. 561, 5Th Floor (Erstwhile Vijaya Bank) Aayakar Bhavan 7Th Floor, Central Accounts M.K. Road Dept., 41/2, M.G. Road Mumbai 400020 Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Assessee By: Shri Ananthan, Ca& Smt. Lalitha Rameswaran, Ca Revenue By: Shri G. Manoj Kumar, Cit-Dr Date Of Hearing: 29.03.2023 Date Of Pronouncement: 25.04.2023 M/S. Bank Of Baroda

For Appellant: Shri Ananthan, CA&For Respondent: Shri G. Manoj Kumar, CIT-DR

Section 115JSection 14ASection 194JSection 36Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

…of Baroda provisions of Banking Regulation Act, hence, any payment in violation of the RBI directions is not allowable as deduction u/s. 37(1) read with Explanation. He also relied on the judgment of Hon’ble Karnataka High Court in the case of Syndicate Bank 261 ITR 528 in which penalty has been confirmed for violation of section 24(4)(a) and 24(4)(b) of the Banking Regulation Act and the penalty paid by the assessee bank for violation of above section was not allowed. 35. The ld. AR reiterated the submissions made before the CIT(A) to which we have noted and he also relied on the judgment of the coordinate Ben…

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), HUBBALLI vs. M/S. KARNATAKA VIKAS GRAMEEN BANK LIMITED, DHARWAD

In the result, the appeal of assessee is partly allowed and the appeal of the revenue is dismissed

ITA 720/BANG/2020[2016-17]Status: DisposedITAT Bangalore05 Dec 2022AY 2016-17

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2016-17

For Appellant: Shri S Ananthan, C.AFor Respondent: Ms. Susan D George, CIT (DR)

Section 143Section 234BSection 250Section 36

…ave not granted. 9. On the other hand, the ld.DR relied on the order CIT(A)/ AO in regard to sec.36(1)(vii)/36(1)(viia) of the Act has been decided by the Hon’ble jurisdictional High Court of Karnataka in the case of CIT Vs. Syndicate Bank [2020[ reported in 422 ITR 460 [kar[ that the issue is decided in favour of the revenue, therefore, reopening made by the lower authorities have been justified and addition should be upheld. 10. We have heard both the parties and perused the entire materials on record and examined the orders of the lower authorities, we observe that additional ground raised by the assessee fi…

M/S KARNATAKA VIKAS GRAMEENA BANK,DHARWAD vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), HUBBALLI

In the result, the appeal of assessee is partly allowed and the appeal of the revenue is dismissed

ITA 611/BANG/2020[2016-17]Status: DisposedITAT Bangalore02 Dec 2022AY 2016-17

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2016-17

For Appellant: Shri S Ananthan, C.A, S.V Ravishankar, AdvocateFor Respondent: Ms. Susan D George, CIT (DR)

Section 143Section 234BSection 250Section 36

…ave not granted. 9. On the other hand, the ld.DR relied on the order CIT(A)/ AO in regard to sec.36(1)(vii)/36(1)(viia) of the Act has been decided by the Hon’ble jurisdictional High Court of Karnataka in the case of CIT Vs. Syndicate Bank [2020[ reported in 422 ITR 460 [kar[ that the issue is decided in favour of the revenue, therefore, reopening made by the lower authorities have been justified and addition should be upheld. 10. We have heard both the parties and perused the entire materials on record and examined the orders of the lower authorities, we observe that additional ground raised by the assessee fi…

THE DCIT, CIRCLE-1(3),, AHMEDABAD vs. THE KALUPUR COMMERCIAL CO.-OP. BANK LTD.,, AHMEDABAD

ITA 387/AHD/2020[2015-16]Status: DisposedITAT Ahmedabad11 May 2022AY 2015-16

Bench: Shri P.M. Jagtap, Vice- & Shri T.R. Senthil Kumarassessment Years : 2015-16 The Dcit, The Kalupur Commercial Circle 1(3), Vs Co-Op. Bank Ltd., Ahmedabad Kalupur Bank Bhavan, Nr. Income Tax, Ashram Road, Ahmedabad 380009 Pan : Aaaat 9360 R अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Revenue By : Shri Vijay Kumar Jaiswal, Cit-Dr Assessee By : Shri S.N. Soparkar, Sr. Advocate & Shri Parin Shah, Ar सुनवाई क" तार"ख/Date Of Hearing : 04/05/2022 घोषणा क" तार"ख /Date Of Pronouncement: 11/05/2022 आदेश / O R D E R Per P.M. Jagtap, Vice-:

For Appellant: Shri S.N. Soparkar, Sr. Advocate, and Shri Parin Shah, ARFor Respondent: Shri Vijay Kumar Jaiswal, CIT-DR

Section 143(3)

…Scheme for regularizing unauthorized constructions. The payment made for such regularization was therefore clearly in the nature of a ‘compensatory payment' as explained by the Hon'ble Karnataka High Court in the case of Syndicate Bank CIT vs. Syndicate Bank, 261 ITR 528 Under such Scheme, a revised plan would have to be submitted showing the extra coverage and extra use of FSI. The charges being in nature of Impact Fees and Balcony Cover Charges were levied at the time of the revised plan being sanctioned; as in the case of Loknath and Co. (supra). It cannot be said that it was a penalty levied for the infractio…

M/S RAILWAY CO-OP BANK LTD ,MYSORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(1), MYSORE

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

ITA 1542/BANG/2018[2013-14]Status: DisposedITAT Bangalore11 Nov 2021AY 2013-14

Bench: Shri George George K, Jm & Shri B.R.Baskaran, Am

For Appellant: Sri.Ravishankar, AdvocateFor Respondent: Sri.Sankar Ganesh K., JCIT-DR

Section 143(2)Section 144Section 234BSection 36(1)(vii)Section 36(1)(viia)

…The learned Departmental Representative, on the other hand, submitted that the issue in question is squarely covered against the assessee by the judgment of the Hon’ble jurisdictional High Court in the case of CIT & Others v. Syndicate Bank reported in (2020) 422 ITR 460 (Kar.). 7. We have heard rival submissions and perused the material on record. The Hon’ble jurisdictional High Court in the case of CIT & Others v. Syndicate Bank (supra) had held that condition precedent for claiming deduction u/s 36(1)(viia) of the I.T.Act is that a provision for bad and doubtful debt should be made in the accounts of the asse…

THE COMMISSIONER OF INCOME-TAX vs. THE VYSYA BANK LTD,

In the result, the impugned order of the tribunal

ITA/4/2015HC Karnataka02 Mar 2021

Bench: ALOK ARADHE,ASHOK S.KINAGI

Section 10Section 115JSection 143(3)Section 260Section 260ASection 36(1)(vii)Section 36(1)(viia)Section 37(1)

…software, hardware and networking of computer etc., therefore, the expenditure is capital in nature. It is also submitted that second substantial question of law has been answered against the revenue in 'COMMISSIONER OF INCOME TAX VS. SYNDICATE BANK', 422 ITR 460 (KAR). In support of aforesaid submissions, reliance has been placed on decision of the Supreme Court in 'EMPIRE JUTE CO. LTD. VS. COMMISSIONER OF INCOME TAX', (1980) 3 TAXMAN 69 (SC). 5. On the other hand, learned Senior counsel for the assessee with reference to substantial question of law submitted as follows: (i) The expenditure was…

CIT v. Syndicate Bank

What is CIT v. Syndicate Bank authority for?

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Issues it is cited on

Judgments citing CIT v. Syndicate Bank

DEPUTY COMMISSIONER INCOME TAX NON CORP CIRCLE II MADURAI, MADURAI vs. VIRUDHUNAGAR DISTRICT CENTRAL CO OP BANK LIMITED, VIRUDHUNAGAR

DEPUTY COMMISSIONER OF INCOME TAX NON CORP CIRCLE II MADURAI, MADURAI vs. VIRUDHUNAGAR DISTRICT CENTRAL CO OP BANK LIMITED, VIRUDHUNAGAR

THE VIRUDHUNAGAR DIST CETNRAL CO- OPERATIVE BANK LIMITED,VIRUDHUNAGAR vs. DCIT,-DCAT, MADURAI-2,, VIRUDHUNAGAR

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-2(1)(1), BENGALURU, BENGALURU vs. CANARA BANK, BENGALURU

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-2(1)(1), BENGALURU, BENGALURU vs. CANARA BANK, BENGALURU

CANARA BANK,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE, BENGALURU

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, CUDDALLORE vs. M/S VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD., VILLUPURAM

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. ACIT, CIRCLE-I,, CUDDALORE

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. ACIT, CIRCLE-II,, CUDDALORE

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. DCIT, VILLUPURAM CIRCLE,, VILLUPRUAM

THE VILLUPURAM DISTRICT CENTRAL COOPERATIVE BANK LTD.,,VILLUPURAM vs. DCIT, VILLUPURAM CIRCLE,, VILLUPURAM

THE VILLUPURAM DISTRICT CENTRAL COOPERTATIVE BANK LTD.,,VILLUPURAM vs. DCIT, VILLUPURAM CIRCLE,, VILLUPURAM

THE CUDDALORE DISTRICT CENTRAL CO-OP BANK LTD.,CUDDALORE vs. DCIT CUDDALORE CIRCLE, CUDDALORE

ADDL/JOINT COMMISSIONER OF INCOME TAX (LTU) , BANGALORE vs. M/S VIJAYA BANK , BANGALORE

M/S VIJAYA BANK ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX LTU , BANGALORE

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), HUBBALLI vs. M/S. KARNATAKA VIKAS GRAMEEN BANK LIMITED, DHARWAD

M/S KARNATAKA VIKAS GRAMEENA BANK,DHARWAD vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(1), HUBBALLI

THE DCIT, CIRCLE-1(3),, AHMEDABAD vs. THE KALUPUR COMMERCIAL CO.-OP. BANK LTD.,, AHMEDABAD

M/S RAILWAY CO-OP BANK LTD ,MYSORE vs. THE ASSISTANT COMMISSIONER OF INCOME TAX CIRCLE-1(1), MYSORE

THE COMMISSIONER OF INCOME-TAX vs. THE VYSYA BANK LTD,