South Indian Bank Ltd. v. CIT

438 ITR 1Supreme Court of India2021#132 most cited

What is South Indian Bank Ltd. v. CIT authority for?

The mixed fund theory is affirmed, holding that no disallowance of interest expenditure under Section 14A can be made if the assessee possesses sufficient non-interest bearing funds, such as capital and reserves, to cover investments made in tax-free securities.

508

judgments rely on this decision, according to BharatTax’s citation analysis of 367,164 Indian tax judgments — from 2011 to 2026.

Also referred to as

South Indian Bank Ltd. v. CIT · South Indian Bank · 438 ITR 1 · Section 14A · disallowance of interest expenditure · mixed fund theory · non-interest bearing funds · tax-free investments · exempt income · Section 8D · expenditure relating to exempt income

Also reported as

130 Taxmann.com 178283 Taxmann 17810 SCC 153228 CTR 440

Sections most often in play

Section 14ASection 143(3)Section 115JBSection 8DSection 153ASection 36(1)(viia)Section 36(1)(vii)Section 36(1)(iii)
Read the full judgment

Issues it is cited on

section 10(33)section 80absection 10(15)section 80msection 54esection 14a(1)section 36(1)(viii)section 54ecsection 14a(2)section 36(1)(vii)disallowance under section 14adisallowance of interest expenditure

Judgments citing South Indian Bank Ltd. v. CIT

Shri Gopal Prasad Agrawal, Raipur vs. Income Tax Officer, Ward 2(2), Raipur

In the result, appeal of the assessee is partly allowed

ITA 86/RPR/2022[2014-15]Status: DisposedITAT Raipur11 Jul 2023AY 2014-15

Bench: SHRI RAVISH SOOD (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

For Respondent: Shri Choudhary N.C.Roy, Sr. DR
Section 14Section 14ASection 263

…say that assessee should cooperate with the ld. AO in verification of the issue remand back to the files of AO. 8. Respectfully following the ratio of law as laid down by the Hon’ble Supreme Court in the case South Indian Bank Ld. Vs. CIT, reported in [2021] 438 ITR 1 (SC), followed by the coordinate bench of this Tribunal and other judgments as relied upon by the assessee, we are of the view that if there is no exempt income, no disallowance can be made u/s.14A r.w.r.8D, however, as fairly admitted by the ld. AR that there was a disclosure of exempt income of Rs.2990/-, therefore, the disallowance should be res…

Dcdc Health Services Private Limited, New Delhi vs. ACIT, Circle-7(1), New Delhi

In the result, the Appeal filed by the assessee is allowed

ITA 9525/DEL/2019[2016-17]Status: DisposedITAT Delhi10 Jul 2023AY 2016-17
Section 143(3)Section 14ASection 41

…Co. Ltd. reported in 394 ITR 449 (SC) • CIT Vs. Reliance Industries Ltd. reported in 410 ITR 466 (SC) • PCIT Vs. Sintex Industries Ltd. reported in 403 ITR 418 (Guj) Revenue's SLP was dismissed [255 Taxman171 (SC) ] • South Indian Bank Ltd Vs CIT. reported in 438 ITR 1 (SC) 130 taxmann.com 178(SC) • CIT VS Suzlon Energy Ltd. reported in 354 ITR 630 (Guj.) • CIT Vs Microlabs Ltd. reported in 383 ITR 490 (Kar) • CIT Vs Max India Ltd. reported in 388 ITR 81 (P&H)” 9. Further it is found from the record that for the Financial Year 2015-16 the total amount of interest paid/payable on cash credit facility and other…

The ACIT Cir 6(3), Mumbai vs. M/S. Grasim Industries Ltd, Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 3854/MUM/2006[2005-2006]Status: DisposedITAT Mumbai04 Jul 2023AY 2005-2006

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Shri J.D. Mistri a/wFor Respondent: Dr. Kishor Dhule
Section 142(1)Section 143(2)Section 143(3)Section 250Section 43B

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI AMARJIT SINGH, ACCOUNTANT MEMBER AND SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER ITA no.3517/Mum./2006 (Assessment Year : 2005–06) Grasim Industries Ltd. (Corporate Finance Division) A–2, Aditya Birla Centre ……………. Appellant S.K. Ahire Marg, Worli Mumbai 400 030 PAN – AAACG4464B v/s Dy. Commissioner of Income Tax ……………. Respondent Circle–6(3), Mumbai ITA no.3854/Mum./2006 (Assessment Year : 2005–06) Asstt. Commissioner of Income Tax ……………. Appellant Circle–6(3), Mumbai v/s Grasim Industries Ltd. Century Bhavan, 3rd Floor ……………. Respondent Dr. A.…

M/S. Grasim Industries Ltd., Mumbai vs. DCIT Cir - 6(3), Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 3517/MUM/2006[2005-2006]Status: DisposedITAT Mumbai04 Jul 2023AY 2005-2006

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Shri J.D. Mistri a/wFor Respondent: Dr. Kishor Dhule
Section 142(1)Section 143(2)Section 143(3)Section 250Section 43B

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI AMARJIT SINGH, ACCOUNTANT MEMBER AND SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER ITA no.3517/Mum./2006 (Assessment Year : 2005–06) Grasim Industries Ltd. (Corporate Finance Division) A–2, Aditya Birla Centre ……………. Appellant S.K. Ahire Marg, Worli Mumbai 400 030 PAN – AAACG4464B v/s Dy. Commissioner of Income Tax ……………. Respondent Circle–6(3), Mumbai ITA no.3854/Mum./2006 (Assessment Year : 2005–06) Asstt. Commissioner of Income Tax ……………. Appellant Circle–6(3), Mumbai v/s Grasim Industries Ltd. Century Bhavan, 3rd Floor ……………. Respondent Dr. A.…

Truworth Infotech Private Limited, Jaipur vs. Income Tax Officer, Ward-2(2), Jaipur

In the result, the appeal of the assessee is allowed

ITA 79/JPR/2023[2014-15]Status: DisposedITAT Jaipur04 Jul 2023AY 2014-15

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri S.R. Sharma, CA &For Respondent: Mrs. Monisha Choudhary, Addl. CIT-DR
Section 115JSection 143(2)Section 143(3)Section 14A

…n case of CIT-1 VS. UTI Bank Ltd. (2022) 447 ITR 662/289 Taxmann 238 held that the legal issue relating to disallowance under section 14A was squarely covered by order of Supreme Court in South Indian Bank Ltd. V. CIT [2021] 130 taxmann.com 178/283 Taxman 178/438 ITR 1/10 SCC 153 wherein it was held that since interest free own funds available with the assessee exceeded their investments in tax-free securities, investments would be presumed to be made out of the assessee's own funds and proportionate disallowance was not warranted under section 14A. The Bombay High Court in case Pr. CIT Vs. Shapoorji Pallonji & C…

DCIT Cir. 4(3)(2), Mumbai vs. Morgan Stanley India Co. Pvt. Ltd., Mumbai

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

ITA 2720/MUM/2016[2008-09]Status: DisposedITAT Mumbai30 Jun 2023AY 2008-09
Section 32(1)Section 40Section 40A(2)Section 92Section 92CSection 92C(2)

…terest is unjustified because admittedly assessee had more interest free funds exceeding the investments yielding any tax free income and now this issue stands covered by the judgement of the Hon’ble Supreme Court in the case of South India Bank Ltd vs. CIT – 130 Taxmann.com 178 (SC). Accordingly, ground No.2 is partly allowed. 38. Lastly, with regard to disallowance of lease line charges, VSAT charges paid to stock exchange and transaction charges paid to local depository u/s.40a (ia) by the ld. AO. The ld. AO noted that assessee company has paid transaction charges to BSE / NSE as well as VSAT and lease line ch…

Morgan Stanley India Company P. Ltd, Mumbai vs. Addl CIT 4(3), Mumbai

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

ITA 1714/MUM/2016[2008-09]Status: DisposedITAT Mumbai30 Jun 2023AY 2008-09
Section 32(1)Section 40Section 40A(2)Section 92Section 92CSection 92C(2)

…terest is unjustified because admittedly assessee had more interest free funds exceeding the investments yielding any tax free income and now this issue stands covered by the judgement of the Hon’ble Supreme Court in the case of South India Bank Ltd vs. CIT – 130 Taxmann.com 178 (SC). Accordingly, ground No.2 is partly allowed. 38. Lastly, with regard to disallowance of lease line charges, VSAT charges paid to stock exchange and transaction charges paid to local depository u/s.40a (ia) by the ld. AO. The ld. AO noted that assessee company has paid transaction charges to BSE / NSE as well as VSAT and lease line ch…

DCIT 4(3), Mumbai vs. Jm Morgan Stanley Securities P. Ltd, Mumbai

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

ITA 2637/MUM/2014[2003-04]Status: DisposedITAT Mumbai30 Jun 2023AY 2003-04
Section 32(1)Section 40Section 40A(2)Section 92Section 92CSection 92C(2)

…terest is unjustified because admittedly assessee had more interest free funds exceeding the investments yielding any tax free income and now this issue stands covered by the judgement of the Hon’ble Supreme Court in the case of South India Bank Ltd vs. CIT – 130 Taxmann.com 178 (SC). Accordingly, ground No.2 is partly allowed. 38. Lastly, with regard to disallowance of lease line charges, VSAT charges paid to stock exchange and transaction charges paid to local depository u/s.40a (ia) by the ld. AO. The ld. AO noted that assessee company has paid transaction charges to BSE / NSE as well as VSAT and lease line ch…

Morgan Stanley India Company P.Ltd, Mumbai vs. Asst CIT RG 4(3), Mumbai

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

ITA 1952/MUM/2014[2003-04]Status: DisposedITAT Mumbai30 Jun 2023AY 2003-04
Section 32(1)Section 40Section 40A(2)Section 92Section 92CSection 92C(2)

…terest is unjustified because admittedly assessee had more interest free funds exceeding the investments yielding any tax free income and now this issue stands covered by the judgement of the Hon’ble Supreme Court in the case of South India Bank Ltd vs. CIT – 130 Taxmann.com 178 (SC). Accordingly, ground No.2 is partly allowed. 38. Lastly, with regard to disallowance of lease line charges, VSAT charges paid to stock exchange and transaction charges paid to local depository u/s.40a (ia) by the ld. AO. The ld. AO noted that assessee company has paid transaction charges to BSE / NSE as well as VSAT and lease line ch…

ACIT 4(3), Mumbai vs. Morgan Stanley India Co. Pvt. Ltd., Mumbai

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

ITA 1235/MUM/2014[2009-10]Status: DisposedITAT Mumbai30 Jun 2023AY 2009-10
Section 32(1)Section 40Section 40A(2)Section 92Section 92CSection 92C(2)

…terest is unjustified because admittedly assessee had more interest free funds exceeding the investments yielding any tax free income and now this issue stands covered by the judgement of the Hon’ble Supreme Court in the case of South India Bank Ltd vs. CIT – 130 Taxmann.com 178 (SC). Accordingly, ground No.2 is partly allowed. 38. Lastly, with regard to disallowance of lease line charges, VSAT charges paid to stock exchange and transaction charges paid to local depository u/s.40a (ia) by the ld. AO. The ld. AO noted that assessee company has paid transaction charges to BSE / NSE as well as VSAT and lease line ch…

Morgan Stanley India Company P.Ltd, Mumbai vs. Addl CIT RG 4(3), Mumbai

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

ITA 1018/MUM/2014[2009-10]Status: DisposedITAT Mumbai30 Jun 2023AY 2009-10
Section 32(1)Section 40Section 40A(2)Section 92Section 92CSection 92C(2)

…terest is unjustified because admittedly assessee had more interest free funds exceeding the investments yielding any tax free income and now this issue stands covered by the judgement of the Hon’ble Supreme Court in the case of South India Bank Ltd vs. CIT – 130 Taxmann.com 178 (SC). Accordingly, ground No.2 is partly allowed. 38. Lastly, with regard to disallowance of lease line charges, VSAT charges paid to stock exchange and transaction charges paid to local depository u/s.40a (ia) by the ld. AO. The ld. AO noted that assessee company has paid transaction charges to BSE / NSE as well as VSAT and lease line ch…

Addl CIT RG 4(3), Mumbai vs. Morgan Stanley India Co P. Ltd, Mumbai

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

ITA 831/MUM/2013[2007-08]Status: DisposedITAT Mumbai30 Jun 2023AY 2007-08
Section 32(1)Section 40Section 40A(2)Section 92Section 92CSection 92C(2)

…terest is unjustified because admittedly assessee had more interest free funds exceeding the investments yielding any tax free income and now this issue stands covered by the judgement of the Hon’ble Supreme Court in the case of South India Bank Ltd vs. CIT – 130 Taxmann.com 178 (SC). Accordingly, ground No.2 is partly allowed. 38. Lastly, with regard to disallowance of lease line charges, VSAT charges paid to stock exchange and transaction charges paid to local depository u/s.40a (ia) by the ld. AO. The ld. AO noted that assessee company has paid transaction charges to BSE / NSE as well as VSAT and lease line ch…

Morgan Stanley India Company P.Ltd, Mumbai vs. Addl CIT RG 4(3), Mumbai

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

ITA 7675/MUM/2012[2007-08]Status: DisposedITAT Mumbai30 Jun 2023AY 2007-08
Section 32(1)Section 40Section 40A(2)Section 92Section 92CSection 92C(2)

…terest is unjustified because admittedly assessee had more interest free funds exceeding the investments yielding any tax free income and now this issue stands covered by the judgement of the Hon’ble Supreme Court in the case of South India Bank Ltd vs. CIT – 130 Taxmann.com 178 (SC). Accordingly, ground No.2 is partly allowed. 38. Lastly, with regard to disallowance of lease line charges, VSAT charges paid to stock exchange and transaction charges paid to local depository u/s.40a (ia) by the ld. AO. The ld. AO noted that assessee company has paid transaction charges to BSE / NSE as well as VSAT and lease line ch…

Living Media India Ltd., New Delhi vs. ACIT, Circle-15(2), New Delhi

The appeal is allowed and the consequences shall follow

ITA 7594/DEL/2018[2013-14]Status: DisposedITAT Delhi30 Jun 2023AY 2013-14

Bench: Sh. G. S. Pannu, Hon’Ble & Sh. Anubhav Sharmam/S. Living Media India Ltd. Vs. Acit, K-9, Connaught Circus, Circle-15(2), New Delhi-110001 New Delhi Pan : Aaacl0087H (Appellant) (Respondent)

Section 143(2)Section 143(3)Section 14ASection 37(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL (DELHI BENCH ‘E’ : NEW DELHI) BEFORE SH. G. S. PANNU, HON’BLE PRESIDENT AND SH. ANUBHAV SHARMA, JUDICIAL MEMBER M/s. Living Media India ltd. Vs. ACIT, K-9, Connaught Circus, Circle-15(2), New Delhi-110001 New Delhi PAN : AAACL0087H (APPELLANT) (RESPONDENT) Assessee by Sh. Madhur Aggarwal, Adv. & Shri Shailesh Gupta, CA Revenue by Ms. Garima Sharma, Sr. DR & Shri Jeetender Chand, Sr. DR Date of hearing: 01.06.2023 Date of Pronouncement: 30.06.2023 ORDER PER ANUBHAV SHARMA, JM: The appeal has been filed by the Assessee against order dated 11.09.2018 in appeal no. 86/17-18 in…

Bank of India, Mumbai vs. The Assistant Commissioner of Income Tax-2(1)(1), Mumbai

In the result, appeal of the Revenue is dismissed

ITA 929/MUM/2023[2012-13]Status: DisposedITAT Mumbai28 Jun 2023AY 2012-13

Bench: Shri Vikas Awasthy & Shri Gagan Goyalआअसं.929/मुं/ 2023 ("न.व.2012-13) Bank Of India, 8Th Floor, Taxation Department, Star House, C-5, G.Block, Badra –Kurla Complex, Bandra (East), Mumbai 400 051 Pan: Aaacb-0472-C ...... अपीलाथ" /Appellant बनाम Vs. The Asstt. Commissioner Of Income Tax 2(1)(1),Mumbai. Mumbai. ..... ""तवाद"/Respondent आअसं.973/मुं/ 2023 ("न.व.2012-13) The Asstt. Commissioner Of Income Tax 2(1)(1),Mumbai. Mumbai. ...... अपीलाथ" /Appellant बनाम Vs. Bank Of India, 8Th Floor, Taxation Department, Star House, C-5, G.Block, Badra –Kurla Complex, Bandra (East), Mumbai 400 051 Pan: Aaacb-0472-C ..... ""तवाद"/Respondent Assessee By : Shri C. Naresh Revenue By : Shri H.N.Singh, Cit-Dr सुनवाई क" "त"थ/ Date Of Hearing : 27/06/2023 घोषणा क" "त"थ/ Date Of Pronouncement : 28/06/2023

For Appellant: Shri C. NareshFor Respondent: Shri H.N.Singh, CIT-DR
Section 10Section 14ASection 90

…ified hereinabove." 7. The judgment of the Punjab and Haryana Court in the case of State Bank of Patiala (supra) was also cited with approval by the Supreme Court in a subsequent judgment South Indian Bank Ltd. v. CIT [2021] 130 taxmann.com 178/283 Taxman 178/438 ITR 1 and held as under:- "25. …The Punjab and Haryana High Court, in the case of Pr CIT v. State Bank of Patiala [2017] 88 taxmann.com 667/393 ITR 476 (Punj. & Har.), while adverting to the CBDT Circular, concluded correctly that shares and securities held by a bank are stock-in-trade, and all income received on such shares and securities must be consid…

Essel Mining & Industries Limited, Mumbai vs. Deputy Commissioner of Income Tax - Central Circle 1(4), Mumbai

Appeal is dismissed

ITA 1018/MUM/2018[2014-15]Status: DisposedITAT Mumbai27 Jun 2023AY 2014-15
For Appellant: Shri Yogesh TharFor Respondent: Shri Biswanath Das
Section 143(3)Section 14ASection 153ASection 32ASection 801ASection 80I

…ee for the Assessment Year 2008-09, 2008-09 and 2009-10 in ITA. No. 786/Kol/2013, ITA. No. 1069 & 2064/Kol /2013 and ITA. No. 1004&1294/Kol /2013, (Assessment Year: 2014-15) respectively as well the judgment in the case of South India Bank Ltd. Vs. CIT [2021] 438 ITR 1 (SC) and Assistant Commissioner of Income-tax, Circle 17 (1), New Delhi Vs. Vireet Investment Pvt. Ltd.: [165 ITD 27] (Delhi Trib.) 5.5. Per contra, Ld. Departmental Representative relied upon the order passed by the Assessing Officer and submitted that the Assessing Officer was correct in making the additions under Section 14A of the Act as per m…

DCIT Cir. 6 (3), Mumbai vs. M/S. Grasim Industries Ltd., Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 4337/MUM/2005[2004-2005]Status: DisposedITAT Mumbai23 Jun 2023AY 2004-2005

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Shri J.D. Mistri a/wFor Respondent: Dr. Kishore Dhule
Section 142(1)Section 143(2)Section 143(3)Section 250Section 43BSection 80Section 80HSection 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI AMARJIT SINGH, ACCOUNTANT MEMBER AND SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER ITA no.3439/Mum./2005 (Assessment Year : 2004–05) Grasim Industries Ltd. (Corporate Finance Division) A–2, Aditya Birla Centre ……………. Appellant S.K. Ahire Marg, Worli Mumbai 400 030 PAN – AAACG4464B v/s Dy. Commissioner of Income Tax ……………. Respondent Circle–6(3), Mumbai ITA no.4337/Mum./2005 (Assessment Year : 2004–05) Dy. Commissioner of Income Tax ……………. Appellant Circle–6(3), Mumbai v/s Grasim Industries Ltd. Century Bhavan, 3rd Floor ……………. Respondent Dr. A.B.…

M/S. Grasim Industries Ltd., Mumbai vs. DCIT CIT Cir. 6(3), Mumbai

In the result, the appeal by the Revenue is dismissed

ITA 3439/MUM/2005[2004-2005]Status: DisposedITAT Mumbai23 Jun 2023AY 2004-2005

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Shri J.D. Mistri a/wFor Respondent: Dr. Kishore Dhule
Section 142(1)Section 143(2)Section 143(3)Section 250Section 43BSection 80Section 80HSection 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI AMARJIT SINGH, ACCOUNTANT MEMBER AND SHRI SANDEEP SINGH KARHAIL, JUDICIAL MEMBER ITA no.3439/Mum./2005 (Assessment Year : 2004–05) Grasim Industries Ltd. (Corporate Finance Division) A–2, Aditya Birla Centre ……………. Appellant S.K. Ahire Marg, Worli Mumbai 400 030 PAN – AAACG4464B v/s Dy. Commissioner of Income Tax ……………. Respondent Circle–6(3), Mumbai ITA no.4337/Mum./2005 (Assessment Year : 2004–05) Dy. Commissioner of Income Tax ……………. Appellant Circle–6(3), Mumbai v/s Grasim Industries Ltd. Century Bhavan, 3rd Floor ……………. Respondent Dr. A.B.…

Dy. Commissioner of Income Tax (Central Circle-1), Raipur vs. M/S. Real Ispat & Power Ltd., Raipur

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

ITA 101/RPR/2021[2013-14]Status: DisposedITAT Raipur14 Jun 2023AY 2013-14

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am आयकर अपील सं./Ita No. 101/Rpr/2021 (Assessment Year: 2013-14) Dy. Commissioner Of Income Tax Vs M/S Real Ispat & Power Ltd. (Central Circle-01), Raipur Vrindavan, Opp. Holy Hearts Schools, Raipur (C.G) Pan No. : Aabcr 9986 L (अपीलाथ" /Appellant) (""यथ" / Respondent) .. : Shri G. S. Agarwal, Ca "नधा"रती क" ओर से /Assessee By राज"व क" ओर से /Revenue By : None सुनवाई क" तार"ख / Date Of Hearing : 12/06/2023 घोषणा क" तार"ख/Date Of Pronouncement : 14/06/2023 आदेश / O R D E R Per Arun Khodpia, Am : The Present Appeal Is Directed Against The Order Of Ld. Cit(A)-3, Bhopal Dated 01.09.2021 For The Assessment Year 2013-14. In This Appeal Of Revenue Following Grounds Were Raised. “1. Whether On The Facts & In Law Ld. Cit(A) Was Justified In Deleting The Addition Of Rs. 2,57,13,664/- Made By The Ao U/S 14A R.W.S 8D? 2. Any Other Ground May Be Pressed At The Time Of Hearing.”

For Respondent: None
Section 143(2)Section 14A

…आयकर अपील"य अ"धकरण, रायपुर "यायपीठ, रायपुर IN THE INCOME TAX APPELLATE TRIBUNAL RAIPUR BENCH, RAIPUR "ी र"वश सूद, "या"यक सद"य एवं "ी अ"ण खोड़"पया, लेखा सद"य के सम" । BEFORE SHRI RAVISH SOOD, JM & SHRI ARUN KHODPIA, AM आयकर अपील सं./ITA No. 101/RPR/2021 (Assessment Year: 2013-14) Dy. Commissioner of Income Tax Vs M/s Real Ispat & Power Ltd. (Central Circle-01), Raipur Vrindavan, Opp. Holy Hearts Schools, Raipur (C.G) PAN No. : AABCR 9986 L (अपीलाथ" /Appellant) (""यथ" / Respondent) .. : Shri G. S. Agarwal, CA "नधा"रती क" ओर से /Assessee by राज"व क" ओर से /Revenue by : None सुनवाई क" तार"ख / Date of Hearing : 12/06…

The Karur Vysya Bank Ltd., Karur vs. Additional CIT, Trichy

In the result, appeals filed by the assessee for all assessment years

ITA 931/CHNY/2011[2006-07]Status: DisposedITAT Chennai09 Jun 2023AY 2006-07

Bench: Shri Manjunatha. G & Shri Manomohan Das

For Respondent: Mr. AR.V.Sreenivasan

…ision of ITAT Chennai Benches in the assessee’s own case for AYs 2013-14 reported in 2021 (11) TMI 568 - ITAT Chennai, where the Tribunal by following the decision of the Hon’ble Supreme Court in the case of South Indian Bank Ltd. v. CIT reported in [2021] 438 ITR 1 (SC) held that provisions of Sec.14A of the ITA Nos.902, 903, 905 & 907/Chny/2010 & ITA Nos.930 & 931/Chny/2011 :: 6 :: Act r.w.r.8D of the IT Rules, 1962, is not applicable in the case of banking companies, where the exempt income has been offered as business income. Therefore, he submitted that the additions made by the AO towards estimated d…