Sumitomo Mitsui Banking\nCorporation Ltd. v. DCTI

CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK,MUMBAI vs. THE DY-CIT (INT. TAXATION)-2(1)(1), MUMBAI

Accordingly these grounds are dismissed as not pressed

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

…heard the parties and perused the material on record. The ld. AR before us submitted that this is a recurring issue and that the same is covered by the decision of the Special Bench of Tribunal in the case of Sumitomo Mitsui Banking Corporation Ltd. vs. DCTI 136 ITR 66 (Mum-Trib-SB) and that the Co-ordinate Bench in assessee's case has been consistently holding the issue in favour of the assessee. We notice that in the latest decision in assessee's own case for AY 2006- 07 to 2009-10 dated 11.09.2023 the Co-ordinate Bench has considered the similar issue where it has been held that “8. We find that the issue is…

CREDIT AGRICOLE CORPORATE & INVESTMENT BANK,MUMBAI vs. THE DY.CIT OF INCOME TAX (INTERNATIONSL TAXATION) -2(1) (1) , MUMBAI

Accordingly these grounds are dismissed as not pressed

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

…heard the parties and perused the material on record. The ld. AR before us submitted that this is a recurring issue and that the same is covered by the decision of the Special Bench of Tribunal in the case of Sumitomo Mitsui Banking Corporation Ltd. vs. DCTI 136 ITR 66 (Mum-Trib-SB) and that the Co-ordinate Bench in assessee's case has been consistently holding the issue in favour of the assessee. We notice that in the latest decision in assessee's own case for AY 2006- 07 to 2009-10 dated 11.09.2023 the Co-ordinate Bench has considered the similar issue where it has been held that “8. We find that the issue is…

CREDIT AGRICOLE CORPORATE & INVESTMENT BANK,MUMBAI vs. THE JT CIT (INTERNATIONAL TAXATIONA), MUMBAI

Accordingly these grounds are dismissed as not pressed

…ard the parties and perused the material on record. The ld. AR before\nus submitted that this is a recurring issue and that the same is covered by the\ndecision of the Special Bench of Tribunal in the case of Sumitomo Mitsui Banking\nCorporation Ltd. vs. DCTI 136 ITR 66 (Mum-Trib-SB) and that the Co-ordinate\nBench in assessee's case has been consistently holding the issue in favour of the\nassessee. We notice that in the latest decision in assessee's own case for AY 2006-\n07 to 2009-10 dated 11.09.2023 the Co-ordinate Bench has considered the similar\nissue where it has been held that\n“8. We find that the issu…

CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK,MUMBAI vs. ACIT (IT) 2 (1)(1), MUMBAI

Accordingly these grounds are dismissed as not pressed

…ard the parties and perused the material on record. The ld. AR before\nus submitted that this is a recurring issue and that the same is covered by the\ndecision of the Special Bench of Tribunal in the case of Sumitomo Mitsui Banking\nCorporation Ltd. vs. DCTI 136 ITR 66 (Mum-Trib-SB) and that the Co-ordinate\nBench in assessee's case has been consistently holding the issue in favour of the\nassessee. We notice that in the latest decision in assessee's own case for AY 2006-\n07 to 2009-10 dated 11.09.2023 the Co-ordinate Bench has considered the similar\nissue where it has been held that\n“8. We find that the issu…

CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK,MUMBAI vs. DCIT (IT) 2(1)(1), MUMBAI

Accordingly these grounds are dismissed as not pressed

…ard the parties and perused the material on record. The ld. AR before\nus submitted that this is a recurring issue and that the same is covered by the\ndecision of the Special Bench of Tribunal in the case of Sumitomo Mitsui Banking\nCorporation Ltd. vs. DCTI 136 ITR 66 (Mum-Trib-SB) and that the Co-ordinate\nBench in assessee's case has been consistently holding the issue in favour of the\nassessee. We notice that in the latest decision in assessee's own case for AY 2006-\n07 to 2009-10 dated 11.09.2023 the Co-ordinate Bench has considered the similar\nissue where it has been held that\n“8. We find that the issu…

CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK,MUMBAI vs. DCIT (IT) 2(1)(1), MUMBAI

Accordingly these grounds are dismissed as not pressed

…ard the parties and perused the material on record. The ld. AR before\nus submitted that this is a recurring issue and that the same is covered by the\ndecision of the Special Bench of Tribunal in the case of Sumitomo Mitsui Banking\nCorporation Ltd. vs. DCTI 136 ITR 66 (Mum-Trib-SB) and that the Co-ordinate\nBench in assessee's case has been consistently holding the issue in favour of the\nassessee. We notice that in the latest decision in assessee's own case for AY 2006-\n07 to 2009-10 dated 11.09.2023 the Co-ordinate Bench has considered the similar\nissue where it has been held that\n“8. We find that the issu…

CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK,MUMBAI vs. DCIT (IT) 2(1)(1), MUMBAI

Accordingly these grounds are dismissed as not pressed

…ard the parties and perused the material on record. The ld. AR before\nus submitted that this is a recurring issue and that the same is covered by the\ndecision of the Special Bench of Tribunal in the case of Sumitomo Mitsui Banking\nCorporation Ltd. vs. DCTI 136 ITR 66 (Mum-Trib-SB) and that the Co-ordinate\nBench in assessee's case has been consistently holding the issue in favour of the\nassessee. We notice that in the latest decision in assessee's own case for AY 2006-\n07 to 2009-10 dated 11.09.2023 the Co-ordinate Bench has considered the similar\nissue where it has been held that\n“8. We find that the issu…

DCIT (IT) 2(1)(1), MUMBAI vs. CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK, MUMBAI

Accordingly these grounds are dismissed as not pressed

…ard the parties and perused the material on record. The ld. AR before\nus submitted that this is a recurring issue and that the same is covered by the\ndecision of the Special Bench of Tribunal in the case of Sumitomo Mitsui Banking\nCorporation Ltd. vs. DCTI 136 ITR 66 (Mum-Trib-SB) and that the Co-ordinate\nBench in assessee's case has been consistently holding the issue in favour of the\nassessee. We notice that in the latest decision in assessee's own case for AY 2006-\n07 to 2009-10 dated 11.09.2023 the Co-ordinate Bench has considered the similar\nissue where it has been held that\n“8. We find that the issu…

ADIT (IT) 1(2), MUMBAI vs. CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK, MUMBAI

Accordingly these grounds are dismissed as not pressed

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

…heard the parties and perused the material on record. The ld. AR before us submitted that this is a recurring issue and that the same is covered by the decision of the Special Bench of Tribunal in the case of Sumitomo Mitsui Banking Corporation Ltd. vs. DCTI 136 ITR 66 (Mum-Trib-SB) and that the Co-ordinate Bench in assessee's case has been consistently holding the issue in favour of the assessee. We notice that in the latest decision in assessee's own case for AY 2006- 07 to 2009-10 dated 11.09.2023 the Co-ordinate Bench has considered the similar issue where it has been held that “8. We find that the issue is…

CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK,MUMBAI vs. DCIT (IT) 2(1)(1), MUMBAI

Accordingly these grounds are dismissed as not pressed

…ard the parties and perused the material on record. The ld. AR before\nus submitted that this is a recurring issue and that the same is covered by the\ndecision of the Special Bench of Tribunal in the case of Sumitomo Mitsui Banking\nCorporation Ltd. vs. DCTI 136 ITR 66 (Mum-Trib-SB) and that the Co-ordinate\nBench in assessee's case has been consistently holding the issue in favour of the\nassessee. We notice that in the latest decision in assessee's own case for AY 2006-\n07 to 2009-10 dated 11.09.2023 the Co-ordinate Bench has considered the similar\nissue where it has been held that\n“8. We find that the issu…

ADIT (IT) 1(2), MUMBAI vs. CALYON BANK, MUMBAI

Bench: Shri Vikas Awasthy& Shri S.Rifaur Rahmanआअसं.9071/मुं/2010 (िन.व. 2006-07) आअसं.3103/मुं/2014 (िन.व. 2007-08) आअसं.1503/मुं/2014 (िन.व. 2008-09) आअसं.1504/मुं/2014 (िन.व. 2009-10) Credit Agricole Corporate & Investment Bank (Formerly Calyon Bank), 11Th Floor, Hoechst House, Nariman Point, Mumbai – 400 021 Pan: Aaccc-3872-B ...... अपीलाथ"/Appellant बनाम Vs. The Asstt. Director Of Income-Tax (International Taxation)-1(2) Mumbai, 1St Floor, Scindia House, Ballard Pier, Mumbai 400 038 ......"ितवादी/Respondent आअसं.4259/मुं/2014 (िन.व. 2007-08) आअसं.1483/मुं/2014 (िन.व. 2008-09) आअसं.1868/मुं/2014 (िन.व. 2009-10) The Asstt. Director Of Income-Tax (International Taxation)-1(2) Mumbai, 1St Floor, Scindia House, Ballard Pier, Mumbai 400 038. ...... अपीलाथ"/Appellant बनाम Vs. Credit Agricole Corporate & Investment Bank (Formerly Calyon Bank), 11Th Floor, Hoechst House

…14(A.Y.2009-10) ITA NO.1483/MUM/2014(A.Y.2008-09) C.O. No.140/MUM/2014 raised in ground No.2 and 3 are recurring. These issues are squarely covered by the decision of Special Bench of Tribunal in the case of Sumitomo Mitsui Banking Corporation Ltd. vs. DCIT, 136 ITR 66(Mum-Trib-SB). The Tribunal has consistently decided this issue in favour of assessee allowing deduction of interest paid to HO. On similar basis bank charges paid to HO/Overseas branches is also allowed. The ld. Counsel for the assessee referred to Tribunal order for Assessment Year 2004-05 dated 10/12/2014(supra) (at page 175 of the paper book) a…

CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK,MUMBAI vs. ASST DIT (IT) 1(2), MUMBAI

Bench: Shri Vikas Awasthy& Shri S.Rifaur Rahmanआअसं.9071/मुं/2010 (िन.व. 2006-07) आअसं.3103/मुं/2014 (िन.व. 2007-08) आअसं.1503/मुं/2014 (िन.व. 2008-09) आअसं.1504/मुं/2014 (िन.व. 2009-10) Credit Agricole Corporate & Investment Bank (Formerly Calyon Bank), 11Th Floor, Hoechst House, Nariman Point, Mumbai – 400 021 Pan: Aaccc-3872-B ...... अपीलाथ"/Appellant बनाम Vs. The Asstt. Director Of Income-Tax (International Taxation)-1(2) Mumbai, 1St Floor, Scindia House, Ballard Pier, Mumbai 400 038 ......"ितवादी/Respondent आअसं.4259/मुं/2014 (िन.व. 2007-08) आअसं.1483/मुं/2014 (िन.व. 2008-09) आअसं.1868/मुं/2014 (िन.व. 2009-10) The Asstt. Director Of Income-Tax (International Taxation)-1(2) Mumbai, 1St Floor, Scindia House, Ballard Pier, Mumbai 400 038. ...... अपीलाथ"/Appellant बनाम Vs. Credit Agricole Corporate & Investment Bank (Formerly Calyon Bank), 11Th Floor, Hoechst House

…14(A.Y.2009-10) ITA NO.1483/MUM/2014(A.Y.2008-09) C.O. No.140/MUM/2014 raised in ground No.2 and 3 are recurring. These issues are squarely covered by the decision of Special Bench of Tribunal in the case of Sumitomo Mitsui Banking Corporation Ltd. vs. DCIT, 136 ITR 66(Mum-Trib-SB). The Tribunal has consistently decided this issue in favour of assessee allowing deduction of interest paid to HO. On similar basis bank charges paid to HO/Overseas branches is also allowed. The ld. Counsel for the assessee referred to Tribunal order for Assessment Year 2004-05 dated 10/12/2014(supra) (at page 175 of the paper book) a…

ASST DIT (IT) 1(2), MUMBAI vs. CREDIT AGRICOLE CORPORATION & INVESTMENTS BANK, MUMBAI

Bench: Shri Vikas Awasthy& Shri S.Rifaur Rahmanआअसं.9071/मुं/2010 (िन.व. 2006-07) आअसं.3103/मुं/2014 (िन.व. 2007-08) आअसं.1503/मुं/2014 (िन.व. 2008-09) आअसं.1504/मुं/2014 (िन.व. 2009-10) Credit Agricole Corporate & Investment Bank (Formerly Calyon Bank), 11Th Floor, Hoechst House, Nariman Point, Mumbai – 400 021 Pan: Aaccc-3872-B ...... अपीलाथ"/Appellant बनाम Vs. The Asstt. Director Of Income-Tax (International Taxation)-1(2) Mumbai, 1St Floor, Scindia House, Ballard Pier, Mumbai 400 038 ......"ितवादी/Respondent आअसं.4259/मुं/2014 (िन.व. 2007-08) आअसं.1483/मुं/2014 (िन.व. 2008-09) आअसं.1868/मुं/2014 (िन.व. 2009-10) The Asstt. Director Of Income-Tax (International Taxation)-1(2) Mumbai, 1St Floor, Scindia House, Ballard Pier, Mumbai 400 038. ...... अपीलाथ"/Appellant बनाम Vs. Credit Agricole Corporate & Investment Bank (Formerly Calyon Bank), 11Th Floor, Hoechst House

…14(A.Y.2009-10) ITA NO.1483/MUM/2014(A.Y.2008-09) C.O. No.140/MUM/2014 raised in ground No.2 and 3 are recurring. These issues are squarely covered by the decision of Special Bench of Tribunal in the case of Sumitomo Mitsui Banking Corporation Ltd. vs. DCIT, 136 ITR 66(Mum-Trib-SB). The Tribunal has consistently decided this issue in favour of assessee allowing deduction of interest paid to HO. On similar basis bank charges paid to HO/Overseas branches is also allowed. The ld. Counsel for the assessee referred to Tribunal order for Assessment Year 2004-05 dated 10/12/2014(supra) (at page 175 of the paper book) a…

CREDIT AGRICOLE CORPORATE AND INVESTMENTS BANK,MUMBAI vs. ASST DIT (IT) 1(2), MUMBAI

Bench: Shri Vikas Awasthy& Shri S.Rifaur Rahmanआअसं.9071/मुं/2010 (िन.व. 2006-07) आअसं.3103/मुं/2014 (िन.व. 2007-08) आअसं.1503/मुं/2014 (िन.व. 2008-09) आअसं.1504/मुं/2014 (िन.व. 2009-10) Credit Agricole Corporate & Investment Bank (Formerly Calyon Bank), 11Th Floor, Hoechst House, Nariman Point, Mumbai – 400 021 Pan: Aaccc-3872-B ...... अपीलाथ"/Appellant बनाम Vs. The Asstt. Director Of Income-Tax (International Taxation)-1(2) Mumbai, 1St Floor, Scindia House, Ballard Pier, Mumbai 400 038 ......"ितवादी/Respondent आअसं.4259/मुं/2014 (िन.व. 2007-08) आअसं.1483/मुं/2014 (िन.व. 2008-09) आअसं.1868/मुं/2014 (िन.व. 2009-10) The Asstt. Director Of Income-Tax (International Taxation)-1(2) Mumbai, 1St Floor, Scindia House, Ballard Pier, Mumbai 400 038. ...... अपीलाथ"/Appellant बनाम Vs. Credit Agricole Corporate & Investment Bank (Formerly Calyon Bank), 11Th Floor, Hoechst House

…14(A.Y.2009-10) ITA NO.1483/MUM/2014(A.Y.2008-09) C.O. No.140/MUM/2014 raised in ground No.2 and 3 are recurring. These issues are squarely covered by the decision of Special Bench of Tribunal in the case of Sumitomo Mitsui Banking Corporation Ltd. vs. DCIT, 136 ITR 66(Mum-Trib-SB). The Tribunal has consistently decided this issue in favour of assessee allowing deduction of interest paid to HO. On similar basis bank charges paid to HO/Overseas branches is also allowed. The ld. Counsel for the assessee referred to Tribunal order for Assessment Year 2004-05 dated 10/12/2014(supra) (at page 175 of the paper book) a…

CREDIT AGRICOLE CORPORATE AND INVESTMENTS BANK,MUMBAI vs. ASST DIT (IT) 1(2), MUMBAI

Bench: Shri Vikas Awasthy& Shri S.Rifaur Rahmanआअसं.9071/मुं/2010 (िन.व. 2006-07) आअसं.3103/मुं/2014 (िन.व. 2007-08) आअसं.1503/मुं/2014 (िन.व. 2008-09) आअसं.1504/मुं/2014 (िन.व. 2009-10) Credit Agricole Corporate & Investment Bank (Formerly Calyon Bank), 11Th Floor, Hoechst House, Nariman Point, Mumbai – 400 021 Pan: Aaccc-3872-B ...... अपीलाथ"/Appellant बनाम Vs. The Asstt. Director Of Income-Tax (International Taxation)-1(2) Mumbai, 1St Floor, Scindia House, Ballard Pier, Mumbai 400 038 ......"ितवादी/Respondent आअसं.4259/मुं/2014 (िन.व. 2007-08) आअसं.1483/मुं/2014 (िन.व. 2008-09) आअसं.1868/मुं/2014 (िन.व. 2009-10) The Asstt. Director Of Income-Tax (International Taxation)-1(2) Mumbai, 1St Floor, Scindia House, Ballard Pier, Mumbai 400 038. ...... अपीलाथ"/Appellant बनाम Vs. Credit Agricole Corporate & Investment Bank (Formerly Calyon Bank), 11Th Floor, Hoechst House

…14(A.Y.2009-10) ITA NO.1483/MUM/2014(A.Y.2008-09) C.O. No.140/MUM/2014 raised in ground No.2 and 3 are recurring. These issues are squarely covered by the decision of Special Bench of Tribunal in the case of Sumitomo Mitsui Banking Corporation Ltd. vs. DCIT, 136 ITR 66(Mum-Trib-SB). The Tribunal has consistently decided this issue in favour of assessee allowing deduction of interest paid to HO. On similar basis bank charges paid to HO/Overseas branches is also allowed. The ld. Counsel for the assessee referred to Tribunal order for Assessment Year 2004-05 dated 10/12/2014(supra) (at page 175 of the paper book) a…

ADIT (IT) 1(2), MUMBAI vs. CALYON BANK, MUMBAI

Bench: Shri Vikas Awasthy& Shri S.Rifaur Rahmanआअसं.9071/मुं/2010 (िन.व. 2006-07) आअसं.3103/मुं/2014 (िन.व. 2007-08) आअसं.1503/मुं/2014 (िन.व. 2008-09) आअसं.1504/मुं/2014 (िन.व. 2009-10) Credit Agricole Corporate & Investment Bank (Formerly Calyon Bank), 11Th Floor, Hoechst House, Nariman Point, Mumbai – 400 021 Pan: Aaccc-3872-B ...... अपीलाथ"/Appellant बनाम Vs. The Asstt. Director Of Income-Tax (International Taxation)-1(2) Mumbai, 1St Floor, Scindia House, Ballard Pier, Mumbai 400 038 ......"ितवादी/Respondent आअसं.4259/मुं/2014 (िन.व. 2007-08) आअसं.1483/मुं/2014 (िन.व. 2008-09) आअसं.1868/मुं/2014 (िन.व. 2009-10) The Asstt. Director Of Income-Tax (International Taxation)-1(2) Mumbai, 1St Floor, Scindia House, Ballard Pier, Mumbai 400 038. ...... अपीलाथ"/Appellant बनाम Vs. Credit Agricole Corporate & Investment Bank (Formerly Calyon Bank), 11Th Floor, Hoechst House

…14(A.Y.2009-10) ITA NO.1483/MUM/2014(A.Y.2008-09) C.O. No.140/MUM/2014 raised in ground No.2 and 3 are recurring. These issues are squarely covered by the decision of Special Bench of Tribunal in the case of Sumitomo Mitsui Banking Corporation Ltd. vs. DCIT, 136 ITR 66(Mum-Trib-SB). The Tribunal has consistently decided this issue in favour of assessee allowing deduction of interest paid to HO. On similar basis bank charges paid to HO/Overseas branches is also allowed. The ld. Counsel for the assessee referred to Tribunal order for Assessment Year 2004-05 dated 10/12/2014(supra) (at page 175 of the paper book) a…

CREDIT AGRICOLE CORPORATE AND INVESTMENT BANK ( FORMERLY CALYON BANK),MUMBAI vs. ADIT (IT) 1(2), MUMBAI

Bench: Shri Vikas Awasthy& Shri S.Rifaur Rahmanआअसं.9071/मुं/2010 (िन.व. 2006-07) आअसं.3103/मुं/2014 (िन.व. 2007-08) आअसं.1503/मुं/2014 (िन.व. 2008-09) आअसं.1504/मुं/2014 (िन.व. 2009-10) Credit Agricole Corporate & Investment Bank (Formerly Calyon Bank), 11Th Floor, Hoechst House, Nariman Point, Mumbai – 400 021 Pan: Aaccc-3872-B ...... अपीलाथ"/Appellant बनाम Vs. The Asstt. Director Of Income-Tax (International Taxation)-1(2) Mumbai, 1St Floor, Scindia House, Ballard Pier, Mumbai 400 038 ......"ितवादी/Respondent आअसं.4259/मुं/2014 (िन.व. 2007-08) आअसं.1483/मुं/2014 (िन.व. 2008-09) आअसं.1868/मुं/2014 (िन.व. 2009-10) The Asstt. Director Of Income-Tax (International Taxation)-1(2) Mumbai, 1St Floor, Scindia House, Ballard Pier, Mumbai 400 038. ...... अपीलाथ"/Appellant बनाम Vs. Credit Agricole Corporate & Investment Bank (Formerly Calyon Bank), 11Th Floor, Hoechst House

…14(A.Y.2009-10) ITA NO.1483/MUM/2014(A.Y.2008-09) C.O. No.140/MUM/2014 raised in ground No.2 and 3 are recurring. These issues are squarely covered by the decision of Special Bench of Tribunal in the case of Sumitomo Mitsui Banking Corporation Ltd. vs. DCIT, 136 ITR 66(Mum-Trib-SB). The Tribunal has consistently decided this issue in favour of assessee allowing deduction of interest paid to HO. On similar basis bank charges paid to HO/Overseas branches is also allowed. The ld. Counsel for the assessee referred to Tribunal order for Assessment Year 2004-05 dated 10/12/2014(supra) (at page 175 of the paper book) a…