Vijaya Bank Ltd. v. Addl. CIT

ASST CIT 2(2)(1), MUMBAI vs. STATE BANK OF INDIA, MUMBAI

In the result appeal filed by the assessee as well as revenue stands partly allowed for statistical purposes

Bench: Smt. Beena Pillai () & Shri Jagadish ()

…wing the Broken Period Expenses, whereas the same is in the nature of Capital outlay towards acquiring investments, given that the main business of the assessee is that of banking and therefore the ratio laid down by the Apex Court in the case of Vijaya Bank (57 Taxmann 152) is squarely applicable in the case of assessee? Re:- Question (a): (i) It is an agreed position between parties that the decision of this Court in American Express International Banking Corporation vs. C.I.T. 258 ITR 601 covers the issue raised herein. (ii) In view of the above, question (a) as formulated does not give rise to any substantial…

STATE BANK OF INDIA,MUMBAI vs. ASST CIT CIR 2(2), MUMBAI

In the result appeal filed by the assessee as well as revenue stands partly allowed for statistical purposes

Bench: Smt. Beena Pillai () & Shri Jagadish ()

…wing the Broken Period Expenses, whereas the same is in the nature of Capital outlay towards acquiring investments, given that the main business of the assessee is that of banking and therefore the ratio laid down by the Apex Court in the case of Vijaya Bank (57 Taxmann 152) is squarely applicable in the case of assessee? Re:- Question (a): (i) It is an agreed position between parties that the decision of this Court in American Express International Banking Corporation vs. C.I.T. 258 ITR 601 covers the issue raised herein. (ii) In view of the above, question (a) as formulated does not give rise to any substantial…

DCIT-2(3)(1), MUMBAI vs. KOTAK MAHINDRA BANK LTD, MUMBAI

In the result, **appeal of the Revenue is dismissed

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar**

…# **IN THE INCOME-TAX APPELLATE TRIBUNAL "E" BENCH, MUMBAI** # **BEFORE SHRI SANDEEP GOSAIN, JUDICIAL MEMBER & SHRI PRABHASH SHANKAR, ACCOUNTANT MEMBER** # **ITANo.3754/MUM/2023 (A.Y. 2019-20)** | Kotak<br>Mahindra<br>Bank | v/s | Assessment Unit, Income Tax | | | |---------------------------------------------------|------|----------------------------------------|--|--| | Limited<br>27<br>BKC,<br>Bandra | बनाम | Department,DCIT-3(2)(2), | | | | Kurla<br>Complex<br>Bandra | | Aaykar Bhavan, Room No. 554,…

DCIT 2(2), MUMBAI vs. STATE BANK OF INDIA, MUMBAI

In the result appeal filed by the assessee for assessment year 2006 – 07 and 2007 – 08 is partly allowed

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal , Jm A.Y.2006-07 [ By Assessee] &

…` IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, AM AND MS KAVITHA RAJAGOPAL , JM A.Y.2006-07 [ by Assessee] & ITA No. 4952/MUM /2013 [By AO ] ITA No 4128/MUM /2014 A.Y.2007-08 [ By AO] & [By Assessee] Vs. State Bank of India The Additional 3rd Floor, Commissionerof Income tax Corporate Centre Circle 2 (2) Mumbai Madam Cama Road Room No 545, Aykar Bhavan Nariman Point Maharishi Karve Road Mumbai 400021 Mumbai 400020 (Appellant) (Respondent) PAN AAACS8577K Assessee by Shri Ketan Ved &Abdulkadir Jawad Wala Revenue by Shri P C Chhhotaray Special Counsel Shri Dr Kishor Dhule…

STATE BANK OF INDIA,MUMBAI vs. ADDL CIT CIR 2(2), MUMBAI

In the result appeal filed by the assessee for assessment

Bench: Shri Prashant Maharishi, Am & Ms Kavitha Rajagopal , Jm

…Page | 1 IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, AM AND MS KAVITHA RAJAGOPAL , JM ITA No. 3868/MUM/2013 [ by Assessee] & ITA No . 4952/MUM /2013 [By AO ] Vs. ITA No 4128/MUM /2014 [ By AO] & ITA no 4105/MUM/2014 [By Assessee] A.Y .2006-07 A.Y .2007-08 State Bank of India 3 r d Floor, Corporate Centre Madam Cama Road Nariman Point Mumbai 400021 The Add it ional Commissionerof Income tax Circle 2 (2) Mumbai Room No 545 , Aykar Bhavan Maharishi Karve Road Mumbai 400020 (Appellant) (Respondent) PAN AAACS8577K Assessee by Shri Ketan Ved &Abdulka…

KOTAK MAHINDRA BANK LIMITED,MUMBAI vs. ADD/JOINT/DEPUTY/ACIT, NATIONAL E-ASSESSMENT CENTRE, DELHI

Bench: Shri Amit Shukla & Shri Gagan Goyal1. Ita No. 4056/Mum/2023 (A.Y.2012-13) 2. Ita No. 4194/Mum/2023 (A.Y.2015-16) 3. Ita No. 3676/Mum/2023 (A.Y.2016-17) 4. Ita No. 4057/Mum/2023 (A.Y.2017-18) 5. Ita No. 3677/Mum/2023 (A.Y.2018-19) Dcit Circle – 2(3) (1), Room No. 552, 5Th Floor, Aayakar Bhavan, M. K. Road, Church Gate, Mumbai- 400 020. ..... Appellant Vs. M/S. Kotak Mahindra Bank Ltd. 27, Bkc, C-27, G-Block, Bandra East, Mumbai-400 051 Pan: Aaack4409J ........ Respondent & 6. C.O. No. 38/Mum/2024(A.Y.2016-17) 7. Ita No. 569/Mum/2023 (A.Y.2017-18) 8. Ita No. 570/Mum/2023 (A.Y.2018-19) M/S. Kotak Mahindra Bank Ltd. 27, Bkc, C-27, G-Block, Bandra East, Mumbai-400 051 Pan: Aaack4409J ..... Appellant 2

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “E”, MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI GAGAN GOYAL, ACCOUNTANT MEMBER 1. ITA No. 4056/Mum/2023 (A.Y.2012-13) 2. ITA No. 4194/Mum/2023 (A.Y.2015-16) 3. ITA No. 3676/Mum/2023 (A.Y.2016-17) 4. ITA No. 4057/Mum/2023 (A.Y.2017-18) 5. ITA No. 3677/Mum/2023 (A.Y.2018-19) DCIT Circle – 2(3) (1), Room No. 552, 5th Floor, Aayakar Bhavan, M. K. Road, Church gate, Mumbai- 400 020. ..... Appellant Vs. M/s. Kotak Mahindra Bank Ltd. 27, BKC, C-27, G-Block, Bandra East, Mumbai-400 051 PAN: AAACK4409J ........ Respondent & 6. C.O. No. 38/Mum/2024(A.Y.2016-17…

DCIT-2(3)(1), MUMBAI vs. KOTAK MAHINDRA BANK LIMITED, MUMBAI

Bench: Shri Amit Shukla & Shri Gagan Goyal1. Ita No. 4056/Mum/2023 (A.Y.2012-13) 2. Ita No. 4194/Mum/2023 (A.Y.2015-16) 3. Ita No. 3676/Mum/2023 (Α.Υ.2016-17) 4. Ita No. 4057/Mum/2023 (Α.Υ.2017-18) 5. Ita No. 3677/Mum/2023 (Α.Υ.2018-19) Dcit Circle – 2(3) (1), Room No. 552, 5Th Floor, Aayakar Bhavan, M. K. Road, Church Gate, Mumbai- 400 020. M/S. Kotak Mahindra Bank Ltd. 27, Вкс, С-27, G-Block, Bandra East, Mumbai-400 051 Pan: Aaack4409J Vs. & Appellant 6. C.O. No. 38/Mum/2024(A.Y.2016-17) 7. Ita No. 569/Mum/2023 (Α.Υ.2017-18) 8. Ita No. 570/Mum/2023 (Α.Υ.2018-19) M/S. Kotak Mahindra Bank Ltd. 27, Вкс, С-27, G-Block, Bandra East, Mumbai-400 051 Pan: Aaack4409J Respondent . Appellant

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “E”, MUMBAI BEFORE SHRI AMIT SHUKLA, JUDICIAL MEMBER AND SHRI GAGAN GOYAL, ACCOUNTANT MEMBER 1. ITA No. 4056/Mum/2023 (A.Y.2012-13) 2. ITA No. 4194/Mum/2023 (A.Y.2015-16) 3. ITA No. 3676/Mum/2023 (Α.Υ.2016-17) 4. ITA No. 4057/Mum/2023 (Α.Υ.2017-18) 5. ITA No. 3677/Mum/2023 (Α.Υ.2018-19) DCIT Circle – 2(3) (1), Room No. 552, 5th Floor, Aayakar Bhavan, M. K. Road, Church gate, Mumbai- 400 020. M/s. Kotak Mahindra Bank Ltd. 27, ВКС, С-27, G-Block, Bandra East, Mumbai-400 051 PAN: AAACK4409J Vs. & Appellant 6. C.O. No. 38/Mum/2024(A.Y.2016-17) 7. ITA No. 569/Mum/2023…

YES BANK LTD.,,MUMBAI vs. DCIT(2)(2)(2), MUMBAI

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal ()

…n allowable deduction?" 4. "Whether on the facts and in the circumstances of the case and in law, Ld. CIT (A) was right in directing to delete BP| without considering the decision of honorable supreme court in the case of Vijaya Bank Ltd. v/s Addl. CIT (1991) 187 ITR 547(S. C.) wherein it is held that BPl is a part of capital outlay for acquisition of securities and hence not an allowable deduction?" 5. "Whether on the facts and in the circumstances of the case and in law, Ld. CIT (A) was right in directing to delete premium amortized without appreciating the fact that the HTM category of Securities are held as i…

ACIT - 2(2)(2), MUMBAI vs. YES BANK LIMITED, MUMBAI

Bench: Shri Om Prakash Kant () & Ms. Kavitha Rajagopal () Acit-2(2)(2), Room No. 545, 5Th Floor, Aayakar Bhavan, Mumbai-400020. Appellant Yes Bank Ltd., 15Th Floor, Yes Bank Tower, Ifc 2, Senapati Bapat Marg, Elphistone (West), Mumbai-400013. Pan No. Aaacy 2068 D Appellant Assessee By Revenue By Date Of Hearing Date Of Pronouncement

…n allowable deduction?" 4. "Whether on the facts and in the circumstances of the case and in law, Ld. CIT (A) was right in directing to delete BP| without considering the decision of honorable supreme court in the case of Vijaya Bank Ltd. v/s Addl. CIT (1991) 187 ITR 547(S. C.) wherein it is held that BPl is a part of capital outlay for acquisition of securities and hence not an allowable deduction?" 5. "Whether on the facts and in the circumstances of the case and in law, Ld. CIT (A) was right in directing to delete premium amortized without appreciating the fact that the HTM category of Securities are held as i…

DCIT-3(4), MUMBAI vs. M/S IDBI BANK LTD , MUMBAI

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

Bench: Shri Kuldip Singh, Hon'Ble & Shri S. Rifaur Rahman, Hon'Bledcit- 3(4) V. M/S. Idbi Bank Ltd 29Th Floor, Center-1 Central Processing Unit (Tds) World Trade Center, Cuffe Parade Plot No. 82/83, Elemach Bldg Mumbai- 400005 Road No. 7, Street No. 15 Midc, Andheri (E) Mumbai- 400093 Pan: Aabci8842G (Appellant) (Respondent) M/S. Idbi Bank Ltd V. Acit/Dcit-Ltu 22Nd Floor, Idbi Tower 29Th Floor, Centre No. 1 Wtc Complex, Cuffe Parade World Trade Centre, Cuffe Parade Mumbai- 400005 Mumbai- 400005 Pan: Aabci8842G (Appellant) (Respondent)

…-18) M/s. IDBI Bank Ltd Expenses, whereas the same is in the nature of Capital outlay towards acquiring investments, given that the main business of he assessee is that of banking and therefore the ratio laid down by the Apex Court in the case of Vijaya Bank (57 Taxmann 152) is squarely applicable in the case of assessee ? ….. ….. 3. Re:- Question (a) : (i) It is an agreed position between parties that the decision of this Court in American Express International Banking Corporation vs. C.I.T. 258 ITR 601 covers the issue raised herein. (ii) In view of the above, question(a) as formulated does not give rise to any…

DCIT 2 (2)(1), MUMBAI vs. STATE BANK OF INDIA (SUCCESSOR TO STATE BANK OF TRAVANCORE), MUMBAI

In the result, the appeal of the assessee is allowed, whereas the appeal of the revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

…ction? "Whether on the facts and in the circumstances of the case and in law, Ld. CIT(A) was right in directing to delete Broken Period Interest without considering the decision of honourable Supreme Court in the case of Vijaya Bank Ltd. V/s Addl. CIT (1991) 187 ITR 547 (S.C) wherein it is held that BPI is a part of capital outlay for acquisition of securities and hence not an allowable deduction? " Whether on the facts and in the circumstances of the case whether the Ld. CIT(A) was correct in law in deleting the disallowance made under Rule 8D(2)(ii) in view of the recent decision of the Hon'ble Supreme Court i…

STATE BANK OF INDIA ,MUMBAI vs. ACIT 2 (2)(1), MUMBAI

In the result, the appeal of the assessee is allowed, whereas the appeal of the revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail ()

…ction? "Whether on the facts and in the circumstances of the case and in law, Ld. CIT(A) was right in directing to delete Broken Period Interest without considering the decision of honourable Supreme Court in the case of Vijaya Bank Ltd. V/s Addl. CIT (1991) 187 ITR 547 (S.C) wherein it is held that BPI is a part of capital outlay for acquisition of securities and hence not an allowable deduction? " Whether on the facts and in the circumstances of the case whether the Ld. CIT(A) was correct in law in deleting the disallowance made under Rule 8D(2)(ii) in view of the recent decision of the Hon'ble Supreme Court i…

YES BANK LIMITED,MUMBAI vs. DCIT 2 (2)(2), MUMBAI

In the result, appeal filed by the learned assessing officer in ITA number 3238/M/2018 for assessment year 2013 –

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

…t in directing to delete BPI without considering the decision of the honourable Supreme Court in the case of Vijaya bank Ltd versus additional Commissioner of income tax ITA No. 3498 to 3500 & 3236 to 3238/Mum/2018 Yes Bank Limited; A.Y. 11-12 to 13-14 (1991) 187 ITR 547 (SC) wherein it is held that the BPI is a part of capital outlay for acquisition of securities and hence not an allowable deduction 7. whether on the facts and circumstances of the case and in law, the learned CIT (A) was right in directing to delete premium amortised without appreciating the fact that the HTM category of securities are held as…

YES BANK LTD.,MUMBAI vs. DCIT 2(2)(2), MUMBAI

In the result, appeal filed by the learned assessing officer in ITA number 3238/M/2018 for assessment year 2013 –

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm

…t in directing to delete BPI without considering the decision of the honourable Supreme Court in the case of Vijaya bank Ltd versus additional Commissioner of income tax ITA No. 3498 to 3500 & 3236 to 3238/Mum/2018 Yes Bank Limited; A.Y. 11-12 to 13-14 (1991) 187 ITR 547 (SC) wherein it is held that the BPI is a part of capital outlay for acquisition of securities and hence not an allowable deduction 7. whether on the facts and circumstances of the case and in law, the learned CIT (A) was right in directing to delete premium amortised without appreciating the fact that the HTM category of securities are held as…