Southern Technologies Ltd. v. JCIT

320 ITR 577Supreme Court of India2010#216 most cited

What is Southern Technologies Ltd. v. JCIT authority for?

The case concerns the allowability of deductions for provisions made under Section 36 of the Income Tax Act, 1961, especially those related to bad and doubtful debts. It distinguishes such deductions from the recognition of interest income on non-performing assets (NPAs).

353

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2010 to 2026.

Also referred to as

Southern Technologies Ltd. v. JCIT · Section 36 deduction · provision for bad and doubtful debts · Section 36(1)(viia) · Section 36(1)(vii) · allowability of provision · MAT section 115JB · non-performing assets · profits and gains of business or profession · bad debt deduction conditions · Income Tax Act 1961

Sections most often in play

Section 36(1)(vii)Section 14ASection 1961Section 115JBSection 37(1)Section 143(3)Section 36(1)(viia)Section 10(34)
Read the full judgment

Issues it is cited on

section 36(2)(v)section 41(4)section 36(1)(viia)section 36(2)section 36(1)(vii)section 36(1)(viii)section 115jb(2)section 10(34)additional depreciationsection 41section 36(1)profits and gains of business or profession

Judgments citing Southern Technologies Ltd. v. JCIT

Housing & Urban Development Corporation Ltd (Hudco), New Delhi vs. Addl. CIT, Range-4, New Delhi

In the result, the appeal of the assessee is partly allowed for

ITA 7629/DEL/2018[2009-10]Status: DisposedITAT Delhi25 Apr 2025AY 2009-10

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Gagan Kumar, AdvFor Respondent: Shri Dayainder Singh Sidhu, CIT-DR
Section 14ASection 36(1)(viia)

…ght perspective which was upheld by the Hon'ble Supreme Court in Vasisth Chay Vyapar (SC) (supra). However, the Hon'ble High Court misdirected itself in equating the facts of the Assessee's case with the case of Southern Technologies Ltd. v. Asstt. CIT [2010] 320 ITR 577 (SC) which was a case of 'deduction on account of provision under section 36 of the Income Tax Act, 1961 ("IT Act") and not the recognition of interest income on the NPA. Before we proceed further, it is necessary to go through these two cases which are the core of the present case. 4. Issue in the case of Southern Technologies Let us first exam…

Housing & Urban Development Corporation Ltd (Hudco), New Delhi vs. Addl. CIT, Special Range-4, New Delhi

In the result, the appeal of the assessee is partly allowed for

ITA 7628/DEL/2018[2008-09]Status: DisposedITAT Delhi25 Apr 2025AY 2008-09

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Gagan Kumar, AdvFor Respondent: Shri Dayainder Singh Sidhu, CIT-DR
Section 14ASection 36(1)(viia)

…ght perspective which was upheld by the Hon'ble Supreme Court in Vasisth Chay Vyapar (SC) (supra). However, the Hon'ble High Court misdirected itself in equating the facts of the Assessee's case with the case of Southern Technologies Ltd. v. Asstt. CIT [2010] 320 ITR 577 (SC) which was a case of 'deduction on account of provision under section 36 of the Income Tax Act, 1961 ("IT Act") and not the recognition of interest income on the NPA. Before we proceed further, it is necessary to go through these two cases which are the core of the present case. 4. Issue in the case of Southern Technologies Let us first exam…

Housing & Urban Development Corporation Ltd (Hudco), New Delhi vs. Addl. CIT, Range-4, New Delhi

In the result, the appeal of the assessee is partly allowed for

ITA 7626/DEL/2018[2005-06]Status: DisposedITAT Delhi25 Apr 2025AY 2005-06

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Gagan Kumar, AdvFor Respondent: Shri Dayainder Singh Sidhu, CIT-DR
Section 14ASection 36(1)(viia)

…ght perspective which was upheld by the Hon'ble Supreme Court in Vasisth Chay Vyapar (SC) (supra). However, the Hon'ble High Court misdirected itself in equating the facts of the Assessee's case with the case of Southern Technologies Ltd. v. Asstt. CIT [2010] 320 ITR 577 (SC) which was a case of 'deduction on account of provision under section 36 of the Income Tax Act, 1961 ("IT Act") and not the recognition of interest income on the NPA. Before we proceed further, it is necessary to go through these two cases which are the core of the present case. 4. Issue in the case of Southern Technologies Let us first exam…

Assistant Commissioner of Income-Tax, Satara vs. The Karad Urban Co. Op. Bank Ltd Karad, Karad

In the result, the appeal of the Revenue is dismissed

ITA 1564/PUN/2024[2018-19]Status: DisposedITAT Pune04 Mar 2025AY 2018-19

Bench: Shri R.K. Panda & Ms. Astha Chandra

For Appellant: Mr. Deepak ChintamanFor Respondent: Shri Amol Khairnar –
Section 143(2)Section 143(3)Section 37

…ssued by the RBI are not intended to regulate the Income Tax Laws and could not over rule the permissible deductions or their exclusions under the Income Tax Act, 1961, as held by the Hon'ble Supreme Court in the case of Southern Technologies Ltd. reported in 320 ITR 577. 2 3. On the facts and circumstances of the case and in law, the Id. CIT(A), has erred in giving relief to the assessee relying on the CBDT's Instruction No.17/2008 dated 26/11/2008 without appreciating the fact that the said instruction merely states that depreciation / appreciation of scrips held under AFS securities is to be aggregated and onl…

Income Tax Officer, Ward-1, Nanded vs. Latur District Central Co Op Bank Ltd, Latur

In the result, the appeal of the Revenue is dismissed

ITA 1222/PUN/2024[2018-19]Status: DisposedITAT Pune28 Jan 2025AY 2018-19
For Appellant: Department byFor Respondent: Date of hearing
Section 143(2)Section 143(3)Section 36(1)(viia)

…r standard assets amounting to Rs.1,09,89,000/- and bad and doubtful debts reserves u/s 36(1)(viia) of the Act amounting to Rs.6,10,00,000/- are capital in nature. Relying on the decision(s) of Hon'ble Supreme Court in the case of Southern Technology Vs. JCIT 320 ITR 577 (SC) and in the case of Catholic Syrian Bank Vs. CIT 343 ITR 270 (SC) and the Hon'ble Madras High Court in the case of T.N. Power Investment Corporation Ltd. Vs. JCIT 280 ITR 491 (Mad.) and observing that the NPA is not same as bad and doubtful debts and mere provision for NPA is not allowable deduction u/s 36(1)(viia) of the Act, the Ld. AO disa…

Dy. Commissioner of Income Tax, Circle-1(1), Pune vs. Bank of Maharashtra, Pune

ITA 428/PUN/2024[2016-17]Status: DisposedITAT Pune15 Jan 2025AY 2016-17

Bench: Shri R. K. Panda & Shri Vinay Bhamore

Section 115JSection 143(1)Section 143(2)Section 143(3)Section 14ASection 36(1)(via)Section 36(1)(viia)

…atment to be given to particular asset, the same would not necessarily hold good for the purposes of income chargeable to tax under the Act. In fact, the Supreme Court in Southern Technologies Limited v. The Joint Commissioner of Income-Tax reported in (2010) 320 ITR 577 has held that the directions of the RBI have nothing to do with computation of Income under the Act. We further find that on the identical issue Karnataka High Court in Karnataka Bank Ltd. v. Assistant Commissioner of Income-Tax 2013 (356) ITR 549 has inter-alia observed as follows: "...That the order passed by the authorities holding that in vie…

Bank of Maharashtra, Pune vs. Asst Commissioner of Income Tax, Circle 1(1), Pune

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

ITA 259/PUN/2024[2016-17]Status: DisposedITAT Pune15 Jan 2025AY 2016-17

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2016-17

For Appellant: Shri S Ananthan & Smt. Abarna CAFor Respondent: Shri Amol Khairnar CIT-DR
Section 115JSection 143(1)Section 143(2)Section 143(3)Section 14ASection 36(1)(via)Section 36(1)(viia)

…atment to be given to particular asset, the same would not necessarily hold good for the purposes of income chargeable to tax under the Act. In fact, the Supreme Court in Southern Technologies Limited v. The Joint Commissioner of Income-Tax reported in (2010) 320 ITR 577 has held that the directions of the RBI have nothing to do with computation of Income under the Act. We further find that on the identical issue Karnataka High Court in Karnataka Bank Ltd. v. Assistant Commissioner of Income-Tax 2013 (356) ITR 549 has inter-alia observed as follows: "...That the order passed by the authorities holding that in vie…

Deputy Commissioner of Income Tax, Circle 4(2), Delhi, I.P.Estate vs. Bureau Veritas Consumer Products Services(India) Pvt. Ltd., Lajpat Nagar

ITA 3158/DEL/2023[2017-18]Status: DisposedITAT Delhi14 Jan 2025AY 2017-18

Bench: Ms. Madhumita Roy & Shri Amitabh Shukla, Accountnat Member [Assessment Year: 2013-14] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue Cross Objection No.63/Chny/2018 (Arising Out Of Ita No.3157/Chny2017) [Assessment Year: 2013-14] M/S Dalmia Cement Bharat Ltd. The Assistant Commissioner Of Dalmiapuram, Income Tax, Circle-1, Tamilnadu-621651 Vs Williams Road, Cantonment, Trichy, Tamil Nadu-620001 Pan- Aadca9414C Assessee Revenue [Assessment Year: 2014-15] The Assistant Commissioner Of M/S Dalmia Cement Bharat Ltd. Income Tax, Circle-1, Dalmiapuram, Williams Road, Vs Tamilnadu, 621651 Cantonment, Trichy, Tamil Nadu-620001 Pan-Aadca9414C Assessee Revenue

Section 14ASection 32(1)(iia)

…’s claim, but the High Court reversed the order of the CIT(A) and the Tribunal. On appeal by the assessee, Hon’ble 8 Apex Court, while reversing the order of the High Court and referring to its earlier ruling in the case of Southern Technologies Ltd. v. JCIT: 320 ITR 577 held that the credit entry in each and every individual debtor’s account was not necessary to constitute actual write off of bad debts. Hon’ble apex Court explained the impact of Explanation to section 36(1)(vii) and the concept of write off as follows: “To understand the above dichotomy, one must understand ‘how to write off’. If an assessee deb…

Assistant Commissioner of Income Tax, Akola Circle, Akola vs. The Buldhana District Central Co-Op Bank Limited, Buldhana

In the result, appeal filed by the revenue is dismissed

ITA 118/NAG/2020[2011-12]Status: DisposedITAT Nagpur12 Dec 2024AY 2011-12

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Manoj G. MoryaniFor Respondent: Shri Sandipkumar Salunke
Section 143(1)Section 45(1)

…nd issue, the interest accrued of non performing assets of the bank, the AO has opined that the same is taxable on accrual basis. In this regard the AO further placed reliance on the judgment of the Hon'ble Apex Court in the case of Southern Technologies Ltd. 320 ITR 577. Upon assessee's appeal, learned CIT (Appeals) referred to the ITAT Vishakhapatnam Bench 8 The Buldhana District Central Co–operative Bank Ltd. ITA no.125/Nag./2020 decision in the case of CIT vs. Durga Urban Cooperative Bank Ltd. (supra) which read as under: "9. The Hon'ble Supreme Court in the case of M/s Southern Technologies Ltd (Supra) diss…

Pr. Commissioner of Income Tax -7, Delhi vs. Punjab National Bank

ITA/193/2024HC Delhi06 Dec 2024

Bench: HON'BLE MR. JUSTICE TUSHAR RAO GEDELA,HON'BLE THE ACTING CHIEF JUSTICE

Section 143(3)Section 14ASection 260ASection 36(1)(viii)Section 43B

…ITA 193/2024 Page 1 of 13 $~2 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision: 06.12.2024 + ITA 193/2024 PR. COMMISSIONER OF INCOME TAX -7, DELHI .....Appellant Through: Mr Puneet Rai, SSC, Mr Ashvini Kumar and Mr Rishabh Nangia, SCs and Mr Nikhil Jain, Advocate. versus PUNJAB NATIONAL BANK .....Respondent Through: Mr S Krishnan and Mr Harshit Chauhan, Advocates. CORAM:…

Goldiam Jewellery Limited, Mumbai vs. ACIT-CC 1(2), Mumbai

In the result the appeal filed by the assessee stands partly allowed with no order as to cost

ITA 3272/MUM/2023[2018-19]Status: DisposedITAT Mumbai27 Nov 2024AY 2018-19

Bench: Shri Sandeep Gosain & Ms Padmavathy Svs. Acit – Cc 1(2) Goldiam Jewellery Ltd Mumbai. G-10, Ground Floor, Gems & Jewellery Complex Ii, Seeps Sez, Andheri East, Mumbai – 400096. Pan/Gir No. Aaccg3424F (Applicant) (Respondent)

Section 147Section 148Section 250Section 36(1)(va)

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH MUMBAI BEFORE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & MS PADMAVATHY S, ACCOUNTANT MEMBER Vs. ACIT – CC 1(2) Goldiam Jewellery Ltd Mumbai. G-10, Ground Floor, Gems and Jewellery Complex II, Seeps Sez, Andheri East, Mumbai – 400096. PAN/GIR No. AACCG3424F (Applicant) (Respondent) Assessee by Shri Prateek Jian Revenue by Shri Nagnath Bimrao Pasale सुनवाई क" तारीख/Date of Hearing 14.11.2024 घोषणा क" तारीख/Date of Pronouncement 27.11.2024 आदेश / ORDER PER SANDEEP GOSAIN, JM: The present appeal has been filed by the assessee challenging the impugned order 19.07.2023, pass…

DCIT (It)-2(1)(2), Air Building, Nariman Point, Mumbai vs. Dbs Bank Limited, Mumbai

ITA 4722/MUM/2023[2015-16]Status: DisposedITAT Mumbai21 Nov 2024AY 2015-16

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Sunil Kumar Singh, Hon'Bleι.Τ.Α. No. 3691/Mum/2023

For Appellant: Shri P.J. Pardiwala/Shri Madhur Agarwal, A/RsFor Respondent: Shri Vivek Permpurna, CIT, D/R
Section 143(3)Section 14ASection 28Section 36Section 36(1)(vii)Section 36(1)(viia)Section 36(2)Section 37(1)Section 44C

…d v. JCIT 280 ITR 491 (Mad), the AO was of the opinion that the RBI guidelines cannot override the statutory provisions of Income-tax. Further heavily relying upon the decision of the Hon'ble Supreme Court in the case of Southern Technologies Limited vs. JCIT 320 ITR 577 (SC), the AO came to the conclusion that the claim of the assessee for bad debt on account of loss on sale of NPA are not bad debt written off as irrecoverable in the accounts and not allowable u/s 36(1)(vii) of the Act. 8. The assessee carried the matter before the ld. CIT(A) but without any success. 9. Before us, the ld. Counsel for the assesse…

Dbs Bank Ltd (Dbs Bank Ltd., India Branches Now Converted Into Dbs Bank India Ltd), Mumbai vs. DCIT (Int Txt)-2(1)(2), Mumbai

In the result, appeal of the assessee in ITA No

ITA 3691/MUM/2023[2015-16]Status: DisposedITAT Mumbai21 Nov 2024AY 2015-16

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Sunil Kumar Singh, Hon’Ble

For Appellant: Shri P.J. Pardiwala/Shri Madhur Agarwal, A/RsFor Respondent: Shri Vivek Permpurna, CIT, D/R
Section 143(3)Section 14ASection 28Section 36Section 36(1)(vii)Section 36(1)(viia)Section 36(2)Section 37(1)Section 44C

…d v. JCIT 280 ITR 491 (Mad), the AO was of the opinion that the RBI guidelines cannot override the statutory provisions of Income-tax. Further heavily relying upon the decision of the Hon’ble Supreme Court in the case of Southern Technologies Limited vs. JCIT 320 ITR 577 (SC), the AO came to the conclusion that the claim of the assessee for bad debt on account of loss on sale of NPA are not bad debt written off as irrecoverable in the accounts and not allowable u/s 36(1)(vii) of the Act. I.T.A. No. 3691/Mum/2023 I.T.A. No. 4722/Mum/2023 6 8. The assessee carried the matter before the ld. CIT(A) but without any s…

Assistant Commissioner, Mumbai vs. Idbi Bank Limited, Mumbai

In the result, the appeal of the revenue bearing ITA No

ITA 5250/MUM/2024[2020-21]Status: DisposedITAT Mumbai14 Nov 2024AY 2020-21

Bench: Shri. Anikesh Banerjee & Smt. Renu Jauhri

For Appellant: Shri Chellamani NareshFor Respondent: Shri Satya Pal Kumar CIT (DR)
Section 115JSection 14Section 143(3)Section 144BSection 14ASection 250Section 36

…rly mentions that the prescribed accounting treatment does not take into account the applicability of I.T. law and decision of Hon'ble Supreme Court in a recent judgment delivered in January, 2010 in the case of M/s. Southern Technologies Ltd. vs. JCIT (2010) 320 ITR 577 (SC) makes it very clear that RBI Guidelines themselves will not decide taxability of the income. Accordingly, the amount of premium amortized in respect of HTM securities of Rs.155,78,68,968/- is disallowed and added back to the total income. In view of the above discussion the hon'ble ITAT is requested to uphold the addition made by the AO.” 14…

DCIT, New Delhi vs. M/S Hudco Ltd., New Delhi

In the result, the appeal of the revenue in ITA No

ITA 3904/DEL/2015[2010-11]Status: DisposedITAT Delhi04 Nov 2024AY 2010-11

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.

For Appellant: Shri Gagan Kumar, AdvFor Respondent: Shri Waseem Arshad, CIT DR &
Section 143(3)

…he Act, he proceeded to bring to tax the interest income of Rs. 3,75,67,456/- on accrual basis. Reliance in this regard was placed by the lower authorities on the decision of the Hon'ble Supreme Court in the case of Southern Technologies Ltd Vs. ACIT reported 320 ITR 577 (SC) . Accordingly, the very same issue was decided against the assessee by the Hon’ble Jurisdictional High Court for AYs 2005-06 to 2009-10 and the said decision of Hon’ble Jurisdictional High Court has been stayed by the Hon'ble Supreme Court vide its order dated 06.08.2018. Hence, the said issue is sub judice before the Hon'ble Supreme Court i…

M/S. Housing & Urban Development Corporation Ltd. (Hudco), New Delhi vs. Addl. CIT, New Delhi

In the result, the appeal of the revenue in ITA No

ITA 3261/DEL/2015[2010-11]Status: DisposedITAT Delhi04 Nov 2024AY 2010-11

Bench: Shri M. Balaganesh & Shri Yogesh Kumar U.S.

For Appellant: Shri Gagan Kumar, AdvFor Respondent: Shri Waseem Arshad, CIT DR &
Section 143(3)

…he Act, he proceeded to bring to tax the interest income of Rs. 3,75,67,456/- on accrual basis. Reliance in this regard was placed by the lower authorities on the decision of the Hon'ble Supreme Court in the case of Southern Technologies Ltd Vs. ACIT reported 320 ITR 577 (SC) . Accordingly, the very same issue was decided against the assessee by the Hon’ble Jurisdictional High Court for AYs 2005-06 to 2009-10 and the said decision of Hon’ble Jurisdictional High Court has been stayed by the Hon'ble Supreme Court vide its order dated 06.08.2018. Hence, the said issue is sub judice before the Hon'ble Supreme Court i…

Bosch Rexroth (India) Pvt. Ltd., Ahmedabad vs. The Income Tax Officer, Ward-1(1)(3), Ahmedabad

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

ITA 448/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad14 Oct 2024AY 2011-12

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. Advocate & ShriFor Respondent: Shri Ankit Jain, Sr. D.R
Section 145ASection 40

…d in (2010) 323 ITR 166 (SC) Volume 323 has held as under:- "6. The first question is no more res integra. Recently, a Division Bench of this Court in the case of Southern Technologies Limited v. Joint Commissioner Of Income Tax, Coimbatore reported in (2010) 320 ITR 577, (in which one of us S.H Kapadia J. was a party) had an occasion to deal with the first question and it has been answered, accordingly, in favour of the assessee, vide paragraph 25, which reads as under (page "Prior to April 1, 2989, the law, as it then stood, took the view that even in cases in which the asssssee(s) makes only a provision in its…

Hagglunds Drives (India) Pvt. Ltd. ( Now Merged in Bosch Rexroth (India) Ltd.), Ahmedabad vs. The Dy.CIT, Circle-1(1)(2), Ahmedabad

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

ITA 931/AHD/2015[2010-11]Status: DisposedITAT Ahmedabad14 Oct 2024AY 2010-11

Bench: Smt. Annapurna Gupta & Shri Siddhartha Nautiyal

For Appellant: Shri S. N. Soparkar, Sr. Advocate & ShriFor Respondent: Shri Ankit Jain, Sr. D.R
Section 145ASection 40

…d in (2010) 323 ITR 166 (SC) Volume 323 has held as under:- "6. The first question is no more res integra. Recently, a Division Bench of this Court in the case of Southern Technologies Limited v. Joint Commissioner Of Income Tax, Coimbatore reported in (2010) 320 ITR 577, (in which one of us S.H Kapadia J. was a party) had an occasion to deal with the first question and it has been answered, accordingly, in favour of the assessee, vide paragraph 25, which reads as under (page "Prior to April 1, 2989, the law, as it then stood, took the view that even in cases in which the asssssee(s) makes only a provision in its…

The Deputy Commissioner of Income Tax, Circle - 2(1), Mangalore vs. Karnataka Bank Limited., Mangalore

In the result, the appeal of the assessee is partly allowed for statistical purposes and the revenue’s appeal is dismissed

ITA 161/PAN/2019[2015-16]Status: DisposedITAT Bangalore30 Sept 2024AY 2015-16

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K., Judciial Member Assessment Year : 2015-16

For Appellant: Shri Ananthan S. & Smt. Lalitha Rameswaran, CAsFor Respondent: Shri D.K. Mishra, CIT(DR)(ITAT), Bengaluru
Section 115JSection 14ASection 234BSection 36(1)(vii)Section 36(1)(viia)Section 40Section 41(4)

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH : BANGALORE BEFORE SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER AND SHRI SOUNDARARAJAN K., JUDCIIAL MEMBER Assessment year : 2015-16 Karnataka Bank Ltd., Head Office, Vs. The Deputy Commissioner Mahaveer Circle, Kankanady, of Income Tax, Mangalore – 575 002. Circle 2(1), PAN : AABCT 5589K Mangalore. APPELLANT RESPONDENT Assessment year : 2015-16 The Deputy Commissioner of Vs. Karnataka Bank Ltd., Income Tax, Mangalore – 575 002. Circle 2(1), Mangalore. PAN : AABCT 5589K APPELLANT RESPONDENT Assessee by : Shri Ananthan S. & Smt. Lalitha Rameswaran, CAs Revenue by : S…

M/S. Karnataka Bank Limited, Mangaluru vs. The Deputy Commissioner of Income Tax. Circle- 2(1), Mangaluru

In the result, the appeal of the assessee is partly allowed for statistical purposes and the revenue’s appeal is dismissed

ITA 1107/BANG/2019[2015-16]Status: DisposedITAT Bangalore30 Sept 2024AY 2015-16

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K., Judciial Member Assessment Year : 2015-16

For Appellant: Shri Ananthan S. & Smt. Lalitha Rameswaran, CAsFor Respondent: Shri D.K. Mishra, CIT(DR)(ITAT), Bengaluru
Section 115JSection 14ASection 234BSection 36(1)(vii)Section 36(1)(viia)Section 40Section 41(4)

…IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH : BANGALORE BEFORE SHRI LAXMI PRASAD SAHU, ACCOUNTANT MEMBER AND SHRI SOUNDARARAJAN K., JUDCIIAL MEMBER Assessment year : 2015-16 Karnataka Bank Ltd., Head Office, Vs. The Deputy Commissioner Mahaveer Circle, Kankanady, of Income Tax, Mangalore – 575 002. Circle 2(1), PAN : AABCT 5589K Mangalore. APPELLANT RESPONDENT Assessment year : 2015-16 The Deputy Commissioner of Vs. Karnataka Bank Ltd., Income Tax, Mangalore – 575 002. Circle 2(1), Mangalore. PAN : AABCT 5589K APPELLANT RESPONDENT Assessee by : Shri Ananthan S. & Smt. Lalitha Rameswaran, CAs Revenue by : S…