PCIT v. Punjab National Bank

140 Taxmann.com 131High Court2022#5414 most cited

What is PCIT v. Punjab National Bank authority for?

Section 14A of the Income-tax Act is not attracted, and dividend income cannot be disallowed, when shares are held as stock-in-trade by banks, with the primary purpose of trading for profit. This applies even if the shares were acquired through an IPO.

21

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2023 to 2026.

Also referred to as

PCIT v. Punjab National Bank · Section 14A · shares held as stock-in-trade · banks · dividend income · disallowance · trading profit · Maxopp Investment Ltd. · IPO

Sections most often in play

Section 14ASection 8DSection 115JBSection 36(1)(viia)Section 36(1)(vii)Section 90Section 91Section 143(3)

Issues it is cited on

rule 8d disallowancesection 36(i)section 100section 80g(1)section 80g(2)(a)section 43dsection 36(2)(v)section 14a disallowancesection 80g(2)section 91section 36(1)(viia)interest on securities

Judgments citing PCIT v. Punjab National Bank

M/S Visaria Securities Pvt Ltd, Mumbai vs. Asst CIT 4 (2), Mumbai

ITA 356/MUM/2020[2013-14]Status: DisposedITAT Mumbai23 Feb 2023AY 2013-14

Bench: Shri Kuldip Singhassessment Year: 2013-14

For Appellant: Shri Niraj Sheth, A.RFor Respondent: Shri Anil Gupta, D.R
Section 142(1)Section 14A

…IN THE INCOME TAX APPELLATE TRIBUNAL, MUMBAI BENCH “SMC”, MUMBAI BEFORE SHRI KULDIP SINGH, JUDICIAL MEMBER Assessment Year: 2013-14 M/s. Visaria Securities Pvt. The Asst. Commissioner Ltd., of Income Tax-4(2), 3-B2, CNeRGY, Range-4(2)(1), Vs. Appasaheb Marathe Marg, Aayakar Bhavan, Prabhadevi, M.K. Road, Mumbai – 400 025 Mumbai - 400020 PAN: AAACV7721L (Appellant) (Respondent) Present for: Assessee by : Shri Niraj Sheth, A.R. Revenue by : Shri Anil Gupta, D.R. Date of Hearing : 31 . 01 . 2023 Date of Pronouncement : 23 . 02 . 2023 O R D E R Per : Kuldip Singh, Judicial Member: The appellant, M/s. Visaria S…