Shihan Bank v. DCIT

144 Taxmann.com 182Income Tax Appellate Tribunal2022#8758 most cited

What is Shihan Bank v. DCIT authority for?

Provisions of Section 28(iv) cannot be applied to treat notional income as income earned by undertaking business activities. Specifically, Section 28(iv) is inapplicable in cases involving expenditure disallowed under Section 44C.

12

judgments rely on this decision, according to BharatTax’s citation analysis of 366,314 Indian tax judgments — from 2023 to 2025.

Also referred to as

Shihan Bank vs DCIT · 144 Taxmann.com 182 · Section 28(iv) · Section 44C · notional income · business activities · expenditure · disallowance · ITAT

Issues it is cited on

Judgments citing Shihan Bank v. DCIT

Credit Agricole Corporate & Investment Bank, Mumbai vs. The Jt CIT (International Taxationa), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1027/MUM/2021[2016-17]Status: DisposedITAT Mumbai20 Mar 2025AY 2016-17

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1165/Mum/2016 (Assessment Year: 2011-12) Dcit (International Taxation)- 1(1)(1), Room No. 114, 1St Floor, Scindia House, N.M. Marg, Ballard Estate, Mumbai-400038. Appellant) Vs. Credit Agricole Corporate & Investment Bank, 11Th & 12Th & 14Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent)

Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SMT BEENA PILLAI, JM & MS PADMAVATHY S, AM I.T. (TP) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate and Investment Bank (Formerly known as 'Calyon Bank') 11th Floor, Hoechst House, Nariman Point, Mumbai-400021. PAN: AACCC3872B Vs. DCIT (International Taxation)- 2(1)(1), 1st Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) ADIT (International Taxation)- 1(2), Room No. 119, 1st Floor, Scindia House, N.M. Marg, Ballard Pier, M…

Credit Agricole Corporate and Investment Bank, Mumbai vs. ACIT (It) 2 (1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 458/MUM/2019[2014-15]Status: DisposedITAT Mumbai20 Mar 2025AY 2014-15

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) 2

Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SMT BEENA PILLAI, JM & MS PADMAVATHY S, AM I.T. (TP) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate and Investment Bank (Formerly known as 'Calyon Bank') 11th Floor, Hoechst House, Nariman Point, Mumbai-400021. PAN: AACCC3872B Vs. DCIT (International Taxation)- 2(1)(1), 1st Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) ADIT (International Taxation)- 1(2), Room No. 119, 1st Floor, Scindia House, N.M. Marg, Ballard Pier, Mum…

Credit Agricole Corporate and Investment Bank, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 2313/MUM/2017[2012-13]Status: DisposedITAT Mumbai20 Mar 2025AY 2012-13

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As ‘Calyon Bank’) 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) 2

Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SMT BEENA PILLAI, JM & MS PADMAVATHY S, AM I.T. (TP) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate and Investment Bank (Formerly known as ‘Calyon Bank’) 11th Floor, Hoechst House, Nariman Point, Mumbai-400021. PAN: AACCC3872B Vs. DCIT (International Taxation)- 2(1)(1), 1st Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) ADIT (International Taxation)- 1(2), Room No. 119, 1st Floor, Scindia House, N.M. Marg, Ballard Pier, M…

Credit Agricole Corporate and Investment Bank, Mumbai vs. DCIT (It) 2(1)(1), Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1273/MUM/2016[2011-12]Status: DisposedITAT Mumbai20 Mar 2025AY 2011-12

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Credit Agricole Corporate & Investment Bank, Vs. 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Appellant) Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) 2

Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SMT BEENA PILLAI, JM & MS PADMAVATHY S, AM I.T. (TP) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate and Investment Bank (Formerly known as 'Calyon Bank') 11th Floor, Hoechst House, Nariman Point, Mumbai-400021. PAN: AACCC3872B Vs. DCIT (International Taxation)- 2(1)(1), 1st Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) ADIT (International Taxation)- 1(2), Room No. 119, 1st Floor, Scindia House, N.M. Marg, Ballard Pier, Mum…

DCIT (It) 2(1)(1), Mumbai vs. Credit Agricole Corporate and Investment Bank, Mumbai

Accordingly these grounds are dismissed as not pressed

ITA 1165/MUM/2016[2011-12]Status: DisposedITAT Mumbai20 Mar 2025AY 2011-12

Bench: Smt Beena Pillai, Jm & Ms Padmavathy S, Am I.T. (Tp) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) Adit (International Taxation)- 1(2), Room No. 119, 1St Floor, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) Credit Agricole Corporate & Investment Bank, Vs.11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent) Ι.Τ.Α. No. 1273/Mum/2016 (Assessment Year: 2011-12) Credit Agricole Corporate & Investment Bank (Formerly Known As 'Calyon Bank') 11Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B Vs. Dcit (International Taxation)- 2(1)(1), 1St Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1165/Mum/2016 (Assessment Year: 2011-12) Dcit (International Taxation)- 1(1)(1), Room No. 114, 1St Floor, Scindia House, N.M. Marg, Ballard Estate, Mumbai-400038. Appellant) Vs. Credit Agricole Corporate & Investment Bank, 11Th & 12Th & 14Th Floor, Hoechst House, Nariman Point, Mumbai-400021. Pan: Aaccc3872B : Respondent)

Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SMT BEENA PILLAI, JM & MS PADMAVATHY S, AM I.T. (TP) A. No. 1479/Mum/2015 (Assessment Year: 2010-11) Credit Agricole Corporate and Investment Bank (Formerly known as 'Calyon Bank') 11th Floor, Hoechst House, Nariman Point, Mumbai-400021. PAN: AACCC3872B Vs. DCIT (International Taxation)- 2(1)(1), 1st Floor, Room No. 136, Scindia House, N.M. Marg, Ballard Pier, Mumbai-400038. Appellant) : Respondent) Ι.Τ.Α. No. 1839/Mum/2015 (Assessment Year: 2010-11) ADIT (International Taxation)- 1(2), Room No. 119, 1st Floor, Scindia House, N.M. Marg, Ballard Pier, M…

Shihan Bank v. DCIT (144 Taxmann.com 182) — Cited in 12 Judgments | BharatTax