CIT v. T.V. Sundaram Iyengar & Sons Ltd.

222 ITR 344Supreme Court of India1996#398 most cited

What is CIT v. T.V. Sundaram Iyengar & Sons Ltd. authority for?

Unclaimed deposits received in the course of trading transactions and sundry credit balances written back are taxable as business income under Section 41(1) of the Income-tax Act, 1961, as they constitute a cessation of trading liability.

223

judgments rely on this decision, according to BharatTax’s citation analysis of 367,514 Indian tax judgments — from 2002 to 2026.

Also referred to as

CIT v. T.V. Sundaram Iyengar & Sons Ltd. · 222 ITR 344 · Section 41(1) · unclaimed trading deposits · sundry credit balances written back · cessation of trading liability · taxability of income · waiver of loan applicability · business income

Sections most often in play

Section 41(1)Section 14ASection 28(iv)Section 143(3)Section 40(a)(ia)Section 115JBSection 133ASection 142(2A)
Read the full judgment

Issues it is cited on

section 2(19aa)waiver of loansection 28(iv)section 43(b)section 43(6)resulting companysection 41(1)section 43(1)section 41demergersection 32(1)(ii)written down value

Judgments citing CIT v. T.V. Sundaram Iyengar & Sons Ltd.

Larsen & Toubro Ltd, Mumbai vs. Addl CIT RG 2(2), Mumbai

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

ITA 3076/MUM/2012[2000-01]Status: DisposedITAT Mumbai29 Oct 2020AY 2000-01
For Appellant: Shri J.D. Mistry, ARFor Respondent: Shri Rajiv Harit CIT, DR
Section 115Section 115JSection 14ASection 37Section 40A(9)Section 42Section 80Section 80HSection 80I

…xisting in the books of the assessee was taken over by another person and, consequently, the liability ceased to exist in so far as the assessee is concerned. The AO after referring to the decision of the Supreme Court in CIT vs. Sunderam Iyengar & Sons Ltd. (222 ITR 344), observed that the Hon’ble Supreme Court has held that the cessation of liability needs to be treated as income of the assessee under section 41(1) of the Act. In the present case, the liability of the assessee has ceased to exist under agreement with the transferee and, therefore, the sum of Rs.51.60 Crores is taxable as income of the assessee.…

The Commissioner of Income Tax vs. M/S Canara Bank

ITA/419/2012HC Karnataka20 Oct 2020

Bench: ALOK ARADHE,H.T. NARENDRA PRASAD

Section 143(1)Section 143(3)Section 260Section 260ASection 263

…ecame assessee's own money. It was also observed that the assessee himself treated the money as his own and taken the amount in the profit and loss account. By placing reliance on decision of the Supreme Court in 'CIT VS. T.V.SUNDARAM IYYENGER AND SONS', 222 ITR 344 (SC), it was held that an amount of Rs.52,77,81,539/- clearly represents a taxable receipt and there is no provision in the Act to allow the same as deduction from total income. Accordingly, the Assessing Officer was directed to withdraw the deduction of Rs.52,77,81,539/-. 4. The assessee thereupon approached the Income Tax Appellate Tri…

Sri. Ravi Shankar Shetty, Bangalore vs. Assistant Commissioner of Income Tax, Circle- 6(3)(1), Bangalore

In the result, the appeal of the assessee is allowed

ITA 28/BANG/2020[2015-16]Status: DisposedITAT Bangalore08 Oct 2020AY 2015-16

Bench: Shri Chandra Poojari, Am & Smt. Beena Pillai , Jm Ita No.28 /Bang/2020 Assessment Year: 2015-16 Shri Ravi Shankar Shetty, Vs. The Assistant Commissioner Of #289, 1St Floor, 15Th Main, Rmv Income-Tax, Circle-6(3)(1), Extension, Bengaluru Bengaluru-560 080. [Pan:Asups 9568B]

Section 234ASection 56(2)(ix)

…of the Act was unjustified and misconceived and the impugned addition made ought to have been deleted. 7. The ld. CIT(A) is not justified in holding that the ratio of the judgment of the Supreme Court in the case of T.V. Sundaram Iyengar and Sons reported in 222 ITR 344(SC) was applicable to the facts of the appellant’s case without appreciating that the said judgment was distinguishable since the amounts were written back by the said assessee and it was claimed that the same was not taxable as it was a capital receipt at the point of receipt whereas in the appellant’s case, the amounts were never written back a…

The Income Tax Officer, Ward-3, Srikakaulam vs. Sri Vasavi Polymers Private Limited`, Rajam

In the result, appeal of the revenue is dismissed

ITA 606/VIZ/2018[2013-14]Status: DisposedITAT Visakhapatnam03 Jun 2020AY 2013-14

Bench: Shri V. Durga Rao& Shri D.S. Sunder Singhआयकर अपील सं./I.T.A.No.606/Viz/2018 (ननधधारण वर्ा/Assessment Year:2013-14) Income Tax Officer Vs M/S Sri Vasavi Polymers P.Ltd. Ward-3 S.No.125 & 126, Anthakapalli Srikakulam Rajam [Pan : Aaecs1849J] (अपीलार्थी/ Appellant) (प्रत्यर्थी/ Respondent) अपीलधथी की ओर से/ Appellant By : Shri S.Ravi Shankar Narayan, Cit, Dr प्रत्यधथी की ओर से / Respondent By : Shri Y.A.Rao, Ar सुनवधई की तधरीख / Date Of Hearing : 12.03.2020 घोर्णध की तधरीख/Date Of Pronouncement : 05.06.2020 आदेश /O R D E R Per Shri D.S.Sunder Singh: This Appeal Is Filed By The Revenue Against The Order Of The Commissioner Of Income Tax (Appeals) [Cit(A)]-9, Hyderabad In Ita No.10300/Cit(A)-9, Hyd/2017-18 Dated 09.08.2018 For The Assessment Year (A.Y.)2013-14. With The Delay Of 1 Day. The Department Has Filed Condonation Petition & Submitted That The Delay Was Due To The 2

For Appellant: Shri S.Ravi Shankar NarayanFor Respondent: Shri Y.A.Rao, AR
Section 143(3)Section 28Section 41(1)Section 43B

…led by assessee for working capital requirements and waiver of any such 0CC loan amount either partly or fully is a revenue receipt u/s. 28(i) of the I.T. Act, in view of the decision of the Apex Court in the case of CITVs, T.V. Sundaramlyengar and Sons Ltd. (222 ITR 344). 3. The Ld. CIT(A) ought to have further considered that the assessee itself carried the loan amount waived of Rs. 1.70 crore to any 'other reserve' instead of capital reserve under the head 'reserves and surplus in the balance sheet as on 31.03.2013 and therefore such benefit is liable to be assessed as income u/s. 28(i) of the I.T. Act. 4. The…

M/S Karnataka Vikas Grameena Bank, Dharwad vs. CIT, Hubli

In the result, appeal filed by assessee stands partly allowed

ITA 636/BANG/2015[2007-08]Status: DisposedITAT Bangalore19 Feb 2020AY 2007-08

Bench: Shri. A. K. Garodia & Smt. Beena Pillai

For Appellant: Mr. Muzaffar Hussain, CIT – DRFor Respondent: 12-02-2020
Section 36Section 36(1)Section 36(1)(viia)

…The amounts represented credit balances in the name of the trading parties and was taken to its P & L a/c. The CIT(A) held Page 10 of 13 ITA 636/Bang/2015, ITA 627/Bang/2015 & ITA 637/Bang/2015 A. Ys : 2007 – 08 & 2011 – 12 that these amounts were not (1996) 222 ITR 344 revenue receipts but were of capital nature. The provisions of s. 41(1) were not attracted in the facts of this case because he assessee’s liability to pay back the amounts to its customers had not ceased. The Tribunal agreed with this view”. (underlining is by us). 19. The Tribunal adverting to the above ruling has rightly deleted the sum of Rs.…

The Karur Vysya Bank Ltd., Karur vs. ACIT, Trichy

In the result, the appeal filed by the assessee-bank is partly allowed

ITA 54/CHNY/2018[2012-13]Status: DisposedITAT Chennai10 Jan 2020AY 2012-13

Bench: Shri N.R.S. Ganesan & Shri S. Jayaramanआयकर अपील सं/.Ita No. 54/Chny/2018 "नधा#रण वष# / Assessment Year : 2012-13 The Karur Vysya Bank Ltd., The Assistant Commissioner Of Registered & Central Office, V. Income Tax, Erode Road, Circle 2(1), Karur 639002. Tiruchirapalli. Pan : Aaact 3373J

For Appellant: Shri S. Ananthan, CAFor Respondent: Shri S. Bharath, CIT
Section 143(3)Section 14A

…case of City Union Bank Ltd. (supra), allowed the same. 18.2 Being aggrieved, the Revenue is in appeal before us in the present appeal. It is contended that in the light of decision of Hon'ble Supreme Court in the case of CIT v. T.V. Sundaram Iyengar [1996] 222 ITR 344 (SC), the balance lying on unclaimed balance account in the bank more than three years ought to be taxed as an income. On the other hand, the ld. Authorised Representative of assessee submitted that the issue is covered in favour of the assessee company by Karnataka High Court in the case of Karnataka Vikas Gramena Bank 2015 (12) TMI 1420 (supra)…

DCIT Circle 2(1), Trichy vs. The Karur Vysya Bank Ltd., Karur

In the result, the appeal filed by the assessee-bank is partly allowed

ITA 3197/CHNY/2017[2012-13]Status: DisposedITAT Chennai10 Jan 2020AY 2012-13

Bench: Shri N.R.S. Ganesan & Shri S. Jayaramanआयकर अपील सं/.Ita No. 54/Chny/2018 "नधा#रण वष# / Assessment Year : 2012-13 The Karur Vysya Bank Ltd., The Assistant Commissioner Of Registered & Central Office, V. Income Tax, Erode Road, Circle 2(1), Karur 639002. Tiruchirapalli. Pan : Aaact 3373J

For Appellant: Shri S. Ananthan, CAFor Respondent: Shri S. Bharath, CIT
Section 143(3)Section 14A

…case of City Union Bank Ltd. (supra), allowed the same. 18.2 Being aggrieved, the Revenue is in appeal before us in the present appeal. It is contended that in the light of decision of Hon'ble Supreme Court in the case of CIT v. T.V. Sundaram Iyengar [1996] 222 ITR 344 (SC), the balance lying on unclaimed balance account in the bank more than three years ought to be taxed as an income. On the other hand, the ld. Authorised Representative of assessee submitted that the issue is covered in favour of the assessee company by Karnataka High Court in the case of Karnataka Vikas Gramena Bank 2015 (12) TMI 1420 (supra)…

Manu Debnath, Howrah vs. D.C.I.T., Circle-48, Kolkata

In the result, the appeal of the assessee is allowed in part

ITA 1830/KOL/2019[2001-02]Status: DisposedITAT Kolkata31 Dec 2019AY 2001-02

Bench: Shri J. Sudhakar Reddy]

Section 250Section 41(1)

…ently the addition can be made u/s 41(1) of the Act. 5. The Hon’ble jurisdictional High Court in the case of Goodricke Group Limited (supra) has at page 12 held as follows: “In the case of Commissioner of Income-tax Vs. T. V. Sundaram Iyengar and Sons Ltd. (222 ITR 344) relied upon by Mr. Bhowmick appearing for the Revenue, the principle that was enunciated has been reflected from the following observations made therein: “In other words, the principle appears to be that it an amount is received in course of trading transaction, even though it is not taxable in the year of receipt as being of revenue character t…

The Supreme Industries Limited, Mumbai vs. ACIT Ltu, Mumbai

In the result, Revenue’s appeal is dismissed and assessee’s appeal is partly allowed

ITA 4673/MUM/2014[2009-10]Status: DisposedITAT Mumbai20 Dec 2019AY 2009-10

Bench: Shri Shamim Yahya & Shri Pawan Singh: A.Y : 2009-10

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Amit Pratap Singh
Section 115JSection 14ASection 32Section 37(1)Section 43(6)Section 45Section 51Section 80

…y credited the forfeiture 9 The Supreme Industries Ltd. ITA Nos. 4673 & 4754/Mum/2014 amount in the Capital Reserve. In this regard, he further placed reliance on the decision of the Hon'ble Apex Court in the case of CIT vs T.V. Sundaram Iyengar & Sons Ltd., 222 ITR 344 (SC). In this regard, he also referred to the decision of the Hon'ble Madras High Court in the case of CIT vs Ramaniyam Homes (P.) Ltd., 384 ITR 530 (Madras). The learned DR submitted that the assessee has wrongly credited the Capital Reserve, rather, it should be taxed under Section 28(iv) of the Act. The learned DR further submitted that what t…

Purna Chandra Biswal, Jajpur vs. Principal CIT, Cuttack

In the result, appeal of the assessee is partly allowed

ITA 200/CTK/2018[2013-14]Status: DisposedITAT Cuttack15 Nov 2019AY 2013-14

Bench: Shri C.M. Garg, Jm & Shri L.P. Sahu, Am आयकर अपीऱ सं./Ita No.200/Ctk/2018 (नििाारण वषा / Assessment Year :2013-2014) Sri Purna Chandra Biswal, Vs. Principal Cit, Cuttack Jakhapura, Jajpur-755019 स्थायी लेखा सं./Panno. : Aclpb 1493 P (अऩीलाथी /Appellant) (प्रत्यथी / Respondent) .. ननधाारिती की ओर से /Assessee By : Shri S.K.Sarangi, Ar िाजस्व की ओर से /Revenue By : Shri S.M.Keshkamat, Citdr

For Appellant: Shri S.K.Sarangi, ARFor Respondent: Shri S.M.Keshkamat, CITDR
Section 143(3)Section 144Section 145Section 145(3)Section 263Section 44ASection 68

…ed on 23.12.2011, (2012) 343 ITR 408 (Del), the Delhi High Court, referring to its judgment in the case of Jay Engineering Works Ltd. v. CIT (22009) 311 ITR 299 (Del) and applying the ratio laid down the case of CIT v. T.V. Sundaram Iyengar & Sons Ltd. (1996) 222 ITR 344 (SC) under sec. 28 of the IT Act, considered the applicability of clause (a) of sub-section (1) of section 41 as to what would constitute remissions or cessation of trading liability. The Hon'ble Court noted that in the reported case, the assessee has not unilaterally written back the accounts of the sundry creditors in its profit and loss accoun…

M/S. Simpson Unitech Wireless (P) Ltd., New Delhi vs. ITO, New Delhi

In the result, the appeals of the assessees are allowed and the appeal of the Revenue is dismissed

ITA 1953/DEL/2014[2009-10]Status: DisposedITAT Delhi08 Nov 2019AY 2009-10

Bench: Shri Amit Shukla & Shri Dr. B.R.R. Kumar

For Appellant: Shri Salil Agrawal, Adv. ShriFor Respondent: Shri S.S. Rana CIT-DR
Section 28Section 3

…of readymade garments is not covered by any of clauses i.e., clause (iiia) to (iiic) of section 28 and therefore, cannot be included while computing deduction under section 80HHC. iv. CIT Vs T.V. Sundaiam Iyengar & Sons Ltd. T19961 88 Taxman 429 (SC)/f19961 222 ITR 344 (SQ/pl9961 136 CTR 444 (SC), where Hon’ble Supreme Court held that amount representing unclaimed credit balances written back to profit and loss account by assessee during assessment year under consideration, could be treated as assessee's income and liable to be taxed. v. Solid Containers Ltd. Vs DCIT f20091 178 Taxman 192 (Bombay)/r20091 308 IT…

M/S. Acorus Unitech Wireless Pvt. Ltd., New Delhi vs. DCIT, New Delhi

In the result, the appeals of the assessees are allowed and the appeal of the Revenue is dismissed

ITA 2989/DEL/2017[2009-10]Status: DisposedITAT Delhi08 Nov 2019AY 2009-10

Bench: Shri Amit Shukla & Shri Dr. B.R.R. Kumar

For Appellant: Shri Salil Agrawal, Adv. ShriFor Respondent: Shri S.S. Rana CIT-DR
Section 28Section 3

…of readymade garments is not covered by any of clauses i.e., clause (iiia) to (iiic) of section 28 and therefore, cannot be included while computing deduction under section 80HHC. iv. CIT Vs T.V. Sundaiam Iyengar & Sons Ltd. T19961 88 Taxman 429 (SC)/f19961 222 ITR 344 (SQ/pl9961 136 CTR 444 (SC), where Hon’ble Supreme Court held that amount representing unclaimed credit balances written back to profit and loss account by assessee during assessment year under consideration, could be treated as assessee's income and liable to be taxed. v. Solid Containers Ltd. Vs DCIT f20091 178 Taxman 192 (Bombay)/r20091 308 IT…

DCIT, New Delhi vs. M/S. Acorus Wireless Unitech Pvt. Ltd., New Delhi

In the result, the appeals of the assessees are allowed and the appeal of the Revenue is dismissed

ITA 2075/DEL/2017[2009-10]Status: DisposedITAT Delhi08 Nov 2019AY 2009-10

Bench: Shri Amit Shukla & Shri Dr. B.R.R. Kumar

For Appellant: Shri Salil Agrawal, Adv. ShriFor Respondent: Shri S.S. Rana CIT-DR
Section 28Section 3

…of readymade garments is not covered by any of clauses i.e., clause (iiia) to (iiic) of section 28 and therefore, cannot be included while computing deduction under section 80HHC. iv. CIT Vs T.V. Sundaiam Iyengar & Sons Ltd. T19961 88 Taxman 429 (SC)/f19961 222 ITR 344 (SQ/pl9961 136 CTR 444 (SC), where Hon’ble Supreme Court held that amount representing unclaimed credit balances written back to profit and loss account by assessee during assessment year under consideration, could be treated as assessee's income and liable to be taxed. v. Solid Containers Ltd. Vs DCIT f20091 178 Taxman 192 (Bombay)/r20091 308 IT…

Shri Navneet Modi, Ranchi vs. DCIT, Circle-2, Ranchi

In the result, both appeals of the assessee are allowed

ITA 106/RAN/2019[2015-16]Status: DisposedITAT Ranchi30 Oct 2019AY 2015-16

Bench: Shri C.M.Garg, Jm & Shri L.P. Sahu, Am आयकर अऩीऱ सं./Ita No.106/Ran/2019 & आयकर अऩीऱ सं./Ita No.53/Ran/2019 (नििाारण वषा / Assessment Year :2015-2016 & 2013-2014) Shri Navneet Modi, Vs. Dcit, Circle-2, Ranchi Modi House, Kanke Dam Side Road, Kanke, Ranchi स्थायी ऱेखा सं./ Pan No. : Actpm 1511 F (अऩीऱाथी /Appellant) (प्रत्यथी / Respondent) .. यनधागररती की ओर से /Assessee By : Shri Devesh Poddar, Advocate राजस्व की ओर से /Revenue By : Shri Inderjeet Singh, Cit(Dr)

For Appellant: Shri Devesh Poddar, AdvocateFor Respondent: Shri Inderjeet Singh, CIT(DR)
Section 143(3)Section 234ASection 271(1)(c)Section 68

…ed on 23.12.2011, (2012) 343 ITR 408 (Del), the Delhi High Court, referring to its judgment in the case of Jay Engineering Works Ltd. v. CIT (22009) 311 ITR 299 (Del) and applying the ratio laid down the case of CIT v. T.V. Sundaram Iyengar & Sons Ltd. (1996) 222 ITR 344 (SC) under sec. 28 of the IT Act, considered the applicability of clause (a) of sub-section (1) of section 41 as to what would constitute remissions or cessation of trading liability. The Hon'ble Court noted that in the reported case, the assessee has not unilaterally written back the accounts of the sundry creditors in its profit and loss accoun…

DCIT Cir 3(3)(1), Mumbai vs. Rama Phosphates Ltd, Mumbai

In the result, this ground of appeal of assessee is allowed for statistical purposes

ITA 4006/MUM/2016[2010-11]Status: DisposedITAT Mumbai16 Sept 2019AY 2010-11

Bench: Shri Shamim Yahya (Am) & Shri Ravish Sood (Jm)

Section 14Section 14A

…ion 28 of the Act as the amount earned is neither a revenue receipt nor intended for revenue account. In this connection, we would like to refer to the decision of the Honourable Supreme Court in the case of CIT vs. T.V. Sundaram Iyengar and Sons Ltd. (1996), 222 ITR 344 wherein the Honourable Supreme Court has laid down that "If the amount is received in the course of trading transactions, even though it is not taxable in the year of receipt as being of capital character, the amount changes its 5 M/s. Rama Phosphates Ltd. character when the amount becomes the assessee's own money because of limitation or by any…

Pawan Kumar Bansal, Hisar vs. ITO, Ward- 5, Hisar

In the result, captioned appeals are allowed

ITA 2322/DEL/2019[2015-16]Status: DisposedITAT Delhi02 Aug 2019AY 2015-16

Bench: Shri N.K. Billaiya & Shri Suchitra Kamble[Assessment Year: 2015-16]

Section 28

…s deduction from the taxable income in the earlier years and would not come within the purview of Section 41(1) of the Act. However, this Court by placing reliance upon the decision of the Apex Court in the matter of CIT v. T.V. Sundaram Iyengar and Sons Ltd. 222 ITR 344 held that the loan was received by the assessee for carrying on its business and therefore, not a loan taken for the purchase of capital assets. Consequently, the decision of this Court in the matter of Mahindra and Mahindra Limited (supra) was distinguished as in the said case the loan was taken for the purchase of capital assets and not for tra…

Sunil Kumar Bansal, Hisar vs. DCIT, Circle Hisar, Hisar

In the result, captioned appeals are allowed

ITA 2321/DEL/2019[2015-16]Status: DisposedITAT Delhi02 Aug 2019AY 2015-16

Bench: Shri N.K. Billaiya & Shri Suchitra Kamble[Assessment Year: 2015-16]

Section 28

…s deduction from the taxable income in the earlier years and would not come within the purview of Section 41(1) of the Act. However, this Court by placing reliance upon the decision of the Apex Court in the matter of CIT v. T.V. Sundaram Iyengar and Sons Ltd. 222 ITR 344 held that the loan was received by the assessee for carrying on its business and therefore, not a loan taken for the purchase of capital assets. Consequently, the decision of this Court in the matter of Mahindra and Mahindra Limited (supra) was distinguished as in the said case the loan was taken for the purchase of capital assets and not for tra…

Anil Kumar Bansal, Hisar vs. ITO, Ward- 1, Hisar

In the result, captioned appeals are allowed

ITA 2320/DEL/2019[2015-16]Status: DisposedITAT Delhi02 Aug 2019AY 2015-16

Bench: Shri N.K. Billaiya & Shri Suchitra Kamble[Assessment Year: 2015-16]

Section 28

…s deduction from the taxable income in the earlier years and would not come within the purview of Section 41(1) of the Act. However, this Court by placing reliance upon the decision of the Apex Court in the matter of CIT v. T.V. Sundaram Iyengar and Sons Ltd. 222 ITR 344 held that the loan was received by the assessee for carrying on its business and therefore, not a loan taken for the purchase of capital assets. Consequently, the decision of this Court in the matter of Mahindra and Mahindra Limited (supra) was distinguished as in the said case the loan was taken for the purchase of capital assets and not for tra…

ACIT Circle 1, Kumbakonam vs. City Union Bank Limited, Kumbakonam

In the result, appeal of the Revenue in ITA 1316/CHNY/2018

ITA 1316/CHNY/2018[2014-15]Status: DisposedITAT Chennai09 Jul 2019AY 2014-15

Bench: Shri George Mathan & Shri Inturi Rama Rao

For Appellant: Shri. S. Ananthan,C.AFor Respondent: Shri. Sailendra Mamidi, IRS
Section 143(3)Section 14ASection 36(1)Section 36(1)(vii)Section 40Section 41(1)

…case of City Union Bank Ltd. (supra), allowed the same. 18.2 Being aggrieved, the Revenue is in appeal before us in the present appeal. It is contended that in the light of decision of Hon'ble Supreme Court in the case of CIT v. T.V. Sundaram Iyengar [1996] 222 ITR 344 (SC), the balance lying on unclaimed balance account in the bank more than three years ought to be taxed as an income. On the other hand, the ld. Authorised Representative of assessee submitted that the issue is covered in favour of the assessee company by Karnataka High Court in the case of Karnataka Vikas Gramena Bank 2015 (12) TMI 1420 (supra)…

ACIT Circle 1, Kumbakonam vs. City Union Bank Limited, Kumbakonam

In the result, appeal of the Revenue in ITA 1316/CHNY/2018

ITA 1315/CHNY/2018[2012-13]Status: DisposedITAT Chennai09 Jul 2019AY 2012-13

Bench: Shri George Mathan & Shri Inturi Rama Rao

For Appellant: Shri. S. Ananthan,C.AFor Respondent: Shri. Sailendra Mamidi, IRS
Section 143(3)Section 14ASection 36(1)Section 36(1)(vii)Section 40Section 41(1)

…case of City Union Bank Ltd. (supra), allowed the same. 18.2 Being aggrieved, the Revenue is in appeal before us in the present appeal. It is contended that in the light of decision of Hon'ble Supreme Court in the case of CIT v. T.V. Sundaram Iyengar [1996] 222 ITR 344 (SC), the balance lying on unclaimed balance account in the bank more than three years ought to be taxed as an income. On the other hand, the ld. Authorised Representative of assessee submitted that the issue is covered in favour of the assessee company by Karnataka High Court in the case of Karnataka Vikas Gramena Bank 2015 (12) TMI 1420 (supra)…