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“interest on securities”

Chapter I - PreliminarySection 2 - DefinitionsSection 2(28B) / ITR Schedule OS681 judgments

The decision most relied on for interest on securities is South Indian Bank Ltd. v. CIT (438 ITR 1), cited in 508 judgments on BharatTax.

Leading authorities on interest on securities

South Indian Bank Ltd. v. CIT
438 ITR 1 · 2021 · Supreme Court
508
citing judgments

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.

CIT v. Punjab State Cooperative Agricultural Development Bank Ltd.
389 ITR 68 · 2016 · High Court
192
citing judgments

Income earned by a cooperative society from investing its surplus funds in short-term deposits and securities is not attributable to its core activities and therefore not eligible for deduction under Section 80P(2)(a)(i) of the Income-tax Act.

CIT v. Microlabs Ltd.
383 ITR 490 · 2016 · High Court
175
citing judgments

If an assessee possesses interest-free funds exceeding investments in tax-free securities, it is presumed that investments are made from these own funds, precluding disallowance of interest expenditure under Section 14A read with Rule 8D(2)(ii). Additionally, weighted deduction under Section 35(2AB) is computed on the gross expenditure incurred, not net expenditure after reducing income earned.

CIT v. Southern Eastern Employees Cooperative Credit Society Ltd.
390 ITR 524 · 2017 · High Court
170
citing judgments

Income from surplus funds invested in short-term deposits and securities by a cooperative credit society is not attributable to its activities and is therefore not eligible for exemption under section 80P(2)(a)(i) of the Income-tax Act.

CIT v. Vijaya Bank
187 ITR 541 · 1991 · Supreme Court
116
citing judgments

The 'broken period interest' paid on securities is considered part of the capital outlay for acquiring those securities and cannot be allowed as a revenue expenditure or business deduction. It must be capitalized.

American Express International Banking Corporation v. CIT
258 ITR 601 · 2002 · High Court
90
citing judgments

Interest paid by banks is allowable as a deduction in computing total income. The decision distinguished the Supreme Court's ruling in Vijaya Bank regarding the deductibility of such interest.

CIT v. Moni Kumar Subba
333 ITR 38 · 2011 · High Court
78
citing judgments

Notional interest on an interest-free security deposit cannot be considered as actual or deemed rent under Section 23(1) of the Act. For determining Annual Letting Value (ALV) under Section 23(1)(a), it must be in accordance with municipal laws, considering extraneous circumstances, but not exceeding the standard rent as per rent control legislation.

1. Bihar State Co-operative Bank Ltd. v. CIT
39 ITR 114 · 1960 · Supreme Court
76
citing judgments

Interest income earned by a co-operative bank from the investment of its surplus funds, including those statutorily required to be placed in approved securities, is attributable to its banking business and qualifies for deduction under Section 80P(2)(a)(i).

Judgments citing interest on securities

M/S. Cifco Finance Ltd., Mumbai vs. ACIT (OSD-II) Cr-7, Mumbai

In the result all 16 appeals related to the assessee are disposed off

ITA 2498/MUM/2006[2001-2002]Status: DisposedITAT Mumbai29 Aug 2022AY 2001-2002

Bench: The Income Tax Appellate Tribunal C Bench Mumbai Before Sri Amit Shukla J M & Prashant Maharishi Am In The Matter Of Cifco Finance Limited, [ Aaacc1765F] Bhupen Chambers, Dalal Street, Mumbai V The Asst Commissioner Of Income Tax Aykar Bhavan 4Th Floor , M K Road Mumbai 20

Section 143Section 147Section 271

facts and in law the CIT (A) erred in confirming disallowance of claim of right of ₹ 279,794/– in respect of interest on securities offered for tax in earlier year on the ground that genuineness of the transaction remains to be proved Page 4 of 50 vii. on the facts ... grounds of appeal is with respect to the disallowance of claim of right of amounting to ₹ 2,79,794 in respect of interest on securities offered for tax in the earlier year on the ground that the genuineness of transactions remain to be proved. The facts show that assessee

M/S. Cifco Finance Ltd., Mumbai vs. ACIT (OSD-II) Cr-7, Mumbai

In the result all 16 appeals related to the assessee are disposed off

ITA 2497/MUM/2006[2000-2001]Status: DisposedITAT Mumbai29 Aug 2022AY 2000-2001

Bench: The Income Tax Appellate Tribunal C Bench Mumbai Before Sri Amit Shukla J M & Prashant Maharishi Am In The Matter Of Cifco Finance Limited, [ Aaacc1765F] Bhupen Chambers, Dalal Street, Mumbai V The Asst Commissioner Of Income Tax Aykar Bhavan 4Th Floor , M K Road Mumbai 20

Section 143Section 147Section 271

facts and in law the CIT (A) erred in confirming disallowance of claim of right of ₹ 279,794/– in respect of interest on securities offered for tax in earlier year on the ground that genuineness of the transaction remains to be proved Page 4 of 50 vii. on the facts ... grounds of appeal is with respect to the disallowance of claim of right of amounting to ₹ 2,79,794 in respect of interest on securities offered for tax in the earlier year on the ground that the genuineness of transactions remain to be proved. The facts show that assessee

M/S. Cifco Finance Ltd., Mumbai vs. ACIT (OSD-II) Cr-7, Mumbai

In the result all 16 appeals related to the assessee are disposed off

ITA 2496/MUM/2006[1999-2000]Status: DisposedITAT Mumbai29 Aug 2022AY 1999-2000

Bench: The Income Tax Appellate Tribunal C Bench Mumbai Before Sri Amit Shukla J M & Prashant Maharishi Am In The Matter Of Cifco Finance Limited, [ Aaacc1765F] Bhupen Chambers, Dalal Street, Mumbai V The Asst Commissioner Of Income Tax Aykar Bhavan 4Th Floor , M K Road Mumbai 20

Section 143Section 147Section 271

facts and in law the CIT (A) erred in confirming disallowance of claim of right of ₹ 279,794/– in respect of interest on securities offered for tax in earlier year on the ground that genuineness of the transaction remains to be proved Page 4 of 50 vii. on the facts ... grounds of appeal is with respect to the disallowance of claim of right of amounting to ₹ 2,79,794 in respect of interest on securities offered for tax in the earlier year on the ground that the genuineness of transactions remain to be proved. The facts show that assessee

The ACIT (OSD-II) Cen RG-7, Mumbai vs. M/S. Cifco Finance Ltd, Mumbai

In the result all 16 appeals related to the assessee are disposed off

ITA 2341/MUM/2006[2000-2001]Status: DisposedITAT Mumbai29 Aug 2022AY 2000-2001

Bench: The Income Tax Appellate Tribunal C Bench Mumbai Before Sri Amit Shukla J M & Prashant Maharishi Am In The Matter Of Cifco Finance Limited, [ Aaacc1765F] Bhupen Chambers, Dalal Street, Mumbai V The Asst Commissioner Of Income Tax Aykar Bhavan 4Th Floor , M K Road Mumbai 20

Section 143Section 147Section 271

facts and in law the CIT (A) erred in confirming disallowance of claim of right of ₹ 279,794/– in respect of interest on securities offered for tax in earlier year on the ground that genuineness of the transaction remains to be proved Page 4 of 50 vii. on the facts ... grounds of appeal is with respect to the disallowance of claim of right of amounting to ₹ 2,79,794 in respect of interest on securities offered for tax in the earlier year on the ground that the genuineness of transactions remain to be proved. The facts show that assessee

ACIT (OSD-II) Cent. RG. - 7, Mumbai vs. M/S. Cifco Finance Ltd., Mumbai

In the result all 16 appeals related to the assessee are disposed off

ITA 2323/MUM/2006[1999-2000]Status: DisposedITAT Mumbai29 Aug 2022AY 1999-2000

Bench: The Income Tax Appellate Tribunal C Bench Mumbai Before Sri Amit Shukla J M & Prashant Maharishi Am In The Matter Of Cifco Finance Limited, [ Aaacc1765F] Bhupen Chambers, Dalal Street, Mumbai V The Asst Commissioner Of Income Tax Aykar Bhavan 4Th Floor , M K Road Mumbai 20

Section 143Section 147Section 271

facts and in law the CIT (A) erred in confirming disallowance of claim of right of ₹ 279,794/– in respect of interest on securities offered for tax in earlier year on the ground that genuineness of the transaction remains to be proved Page 4 of 50 vii. on the facts ... grounds of appeal is with respect to the disallowance of claim of right of amounting to ₹ 2,79,794 in respect of interest on securities offered for tax in the earlier year on the ground that the genuineness of transactions remain to be proved. The facts show that assessee

M/S. Volvo Group India Private Limited (Earlier Known As Volvo India Private Limited), Bengaluru vs. Income Tax Officer (OSD) Large Tax Payers Unit, Bangalore

ITA 498/BANG/2020[2014-15]Status: DisposedITAT Bangalore25 Aug 2022AY 2014-15

Bench: Shri George George K. & Ms. Padmavathy Sassessment Year : 2014-15

For Appellant: Shri Neeraj K. Jain, AdvocateFor Respondent: Shri Bijoy Kumar Panda, CIT(DR)(ITAT), Bengaluru
Section 194CSection 194C(6)Section 201Section 40

Income-tax Act, tax has to be deducted at source by the person responsible for making any payment in the nature of interest on securities at the time of payment. The liability to deduct tax at source was being postponed by making a provision for such payment. In order ... Hindu Undivided family, who is responsible for paying to a resident any income by way of interest other than income by way of interest on securities, shall, at the time of credit of such income to the account of payee or at the time of payment thereof in cash

M/S Stratergic Capital Corporation Pvt Ltd, Mumbai vs. ACIT Circle 2(3)(2), Mumbai

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

ITA 4013/MUM/2019[2012-13]Status: DisposedITAT Mumbai23 Aug 2022AY 2012-13
Section 143(3)Section 37

Accordingly, we direct the ld. AO to give effect to the directions of the ld. CIT(A) to examine the taxability of interest on securities in accordance with law, while giving effect to this order of tribunal. The second part of Ground No. 1 is disposed of accordingly

DCIT-2(2)(1), Mumbai vs. M/S State Bank of India, Mumbai

In the result, the appeal filed by the Revenue is dismissed

ITA 3036/MUM/2019[2015-16]Status: DisposedITAT Mumbai12 Aug 2022AY 2015-16

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2015-16 Dcit-2(2)(1), M/S State Bank Of India Room No. 545, 5Th Floor, (Successor To State Bank Of Aayakar Bhavan, Vs. Bikaner & Jaipur), Mumbai-400020. Fr&T Department, 3Rd Floor, Sbi Bhavan, Nariman Point, Mumbai-400020. Pan No. Aaacs 8577 K (Earlier Aadcs 4750 R) Appellant Respondent Revenue By : Mr. Manoj Kumar, Cit-Dr Assessee By : Mr. Ketan Ved & Ms. Shraddha Jain, Ars Date Of Hearing : 28/07/2022 Date Of Pronouncement : 12/08/2022

For Appellant: Mr. Ketan Ved &For Respondent: Mr. Manoj Kumar, CIT-DR

accounting followed by the r the mercantile system of accounting followed by the r the mercantile system of accounting followed by the assessee interest on securities has to be taxed on accrual assessee interest on securities has to be taxed on accrual assessee interest on securities has to be taxed ... before the Assessing Officer. According to the assessee, the interest of . According to the assessee, the interest of . According to the assessee, the interest of securities was taxable on the due basis. The assessee worked out securities was taxable on the due basis. The assessee worked out securities was taxable

DCIT 14(1)(1), Mumbai vs. Blue Berry Trading Co P.Ltd, Mumbai

In the result appeal of the Revenue is dismissed

ITA 3568/MUM/2016[2011-12]Status: DisposedITAT Mumbai08 Aug 2022AY 2011-12
Section 143(3)Section 73

business of a company (other than a company whose gross total income consists mainly of income which is chargeable under the heads "Interest on securities", "Income from house property", "Capital gains" and "Income from other sources", or a company the principal business of banking or the granting of loans ... clear that one of the exception carved out thereon is, if the gross total income consists mainly of income chargeable under the head “interest on securities”, “income from house property”, “capital gains” and “income from other sources” then the loss incurred on shares would not fall under the ambit

Giraffe Developers Pvt. Ltd., Mumbai vs. Pr. CIT - 9, Mumbai

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

ITA 2663/MUM/2019[2014-15]Status: DisposedITAT Mumbai25 Jul 2022AY 2014-15

Bench: Shri Prashant Maharishi & Shri Pavan Kumar Gadalegiraffe Developers Pvt Vs. Pr. Cit – 9, Ltd Room No. 214, 2Nd 111, G Wing, Akruti Floor, Aayakar Commercial Complex, Bhavan, M.K. Road, Next To Akruti Centre Churchgate, Point, Central Road, Mumbai-400020. Andheri (E), Mumbai- 400093 Pan/Gir No. : Aaccn2778D Appellant .. Respondent Appellant By : Shri.Madhur Agrawal & Shri.Fenil Bhatt.Ar Respondent By : Shri.S.Anbuselvam.Dr Date Of Hearing 13.07.2022 Date Of Pronouncement 25.07.2022 आदेश / O R D E R Per Pavan Kumar Gadale Jm: The Assessee Has Filed The Appeal Against The Order Of Pr. Commissioner Of Income Tax (Appeals)-9, Mumbai Passed U/S 143(3) & 250 Of The Act. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: Shri.Madhur Agrawal &For Respondent: Shri.S.Anbuselvam.DR
Section 139(1)Section 143(1)Section 143(2)Section 143(3)Section 263Section 271ASection 271BSection 40Section 40A(2)Section 92D

meaning of section 263 of the Income Tax Act, 1961. 4.The A.O. observed from Tax Audit Report that the assessee has paid interest on securities amounting to Rs.15,00,00,000/- to M/s. Hum Town Ltd. Which is 100% shareholder in class B shares. However, the assessee has not prepared ... case of Shripan Land Development Vs. CIT 46 SOT 447 [ITAT-Mum], as per the facts reported the assessee has received interest free security deposit against the premises rented to the bank, yet at the time of making assessment the A0 had not made addition on account of notional interest

M/S. Ozone Urban Infra Developers Private Limited, Bangalore vs. The Assistant Commissioner of Income Tax TDS, Circel-2(1), Bangalore

In the result, appeal is allowed in favour of the assessee

ITA 225/BANG/2022[2019-20]Status: DisposedITAT Bangalore12 Jul 2022AY 2019-20

Bench: Shri. George George K & Ms. Padmavathy Sassessment Year : 2019-20 M/S. Ozone Urbana Infra Developers Pvt. Ltd., Vs. Acit Tds, No.30, Ulsoor Road, Bengaluru North, Circle – 2(1), Bengaluru – 560 042. Bengaluru. Pan : Aaecm 5394 G Appellant Respondent Assessee By : Shri. Narendra Kumar Jain, Advocate Revenue By : Dr. Manjunath Karkihalli, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 05.07.2022 Date Of Pronouncement : 12.07.2022

For Appellant: Shri. Narendra Kumar Jain, AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru
Section 131Section 133ASection 194ASection 2Section 201Section 201(1)Section 250

Hindu undivided family, who is responsible for paying to a resident any income by way of interest other than income by way of interest on securities, shall, at the time of credit of such income to the account of the payee or at the time of payment thereof in cash

Anurag Chandra, Noida vs. National Faceless Appeal Centre, Delhi

In the result, appeal of the assessee is allowed

ITA 2407/MUM/2021[2016-2017]Status: DisposedITAT Mumbai29 Jun 2022AY 2016-2017

Bench: Shri Vikas Awasthy, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Tejveer SinghFor Respondent: Shri Mehul Jain
Section 143(3)

Income 5 ITA.NO. 2407/MUM/2021 (A.Y: 2016-17) Shri Anurag Chandra from other sources" (not being income by way of dividends (and "Interest on securities"]), the last day of the previous year of the assessee, As per clause (d) in respect of income chargeable under the head "Profits and gains ... profession not being income referred to in clause (d) and "Income from other sources" (not being income by way of dividends (and "Interest on securities "), the last day of the previous year of the assessee: 7 ITA.NO. 2407/MUM/2021 (A.Y: 2016-17) Shri Anurag Chandra (d) in respect of income chargeable

ACIT 16(2), Mumbai vs. Bsr and Co. LLP, Mumbai

In the result, the appeal of the Revenue is dismissed

ITA 2549/MUM/2018[2013-14]Status: DisposedITAT Mumbai15 Jun 2022AY 2013-14
For Appellant: Sh. Suresh Kabra, CAFor Respondent: Sh. Jagdish Jangid, CIT-DR
Section 142(1)Section 40Section 90

scheme of tax deduction at source applies not only to the amount paid which wholly bears “income” character such as salaries, dividends, interest on securities, etc. but also gross sums, the whole of which may not be income or profits of the recipient, such as payments to contractors

United Breweries Ltd, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-7(1)(1), Bengaluru

ITA 2569/BANG/2017[2013-14]Status: DisposedITAT Bangalore01 Jun 2022AY 2013-14

Bench: Shri N.V. Vasudevan, Vice Preseident & Shri Padmavathy S

For Appellant: Shri K.R. Vasudevan, AdvocateFor Respondent: Shri Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru
Section 143(3)Section 92Section 92B(1)

Income-tax Act, tax has to be deducted at source by the person responsible for making any payment in the nature of interest on securities at the time of payment. The liability to deduct tax at source was being postponed by making a provision for such payment. In order

Hinduja Finance Ltd., Mumbai vs. DCIT, Range -7(1)(2) (Earlier DCIT 6(1)), Mumbai

In the result, this ground of appeal of assessee is dismissed and order of Ld

ITA 7154/MUM/2019[2010-11]Status: DisposedITAT Mumbai20 May 2022AY 2010-11

Bench: Shri Vikas Awasthy & Shri Gagan Goyalhinduja Finance Ltd. 171, Hinduja House, Dr. Annie Besant Road, Worli, Mumbai-400018 Pan: Aagca0533R ...... Appellant Vs. Dy.Cit, Range-7(1)(2) Aayakar Bhavan, M.K. Road, Mumbai-400020. ..... Respondent Appellant By : Sh. Ruturaj Gurjar Respondent By : Sh. B.K. Bagchi, Cit-Dr Date Of Hearing : 25/03/2022 Date Of Pronouncement : 20/05/2022 Order Per Gagan Goyal, A.M: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax (Appeals)-13, Mumbai [Hereinafter Referred To As ‘The Cit (A)’] Vide Order Dated 05.09.2019 For The Assessment Year (Ay) 2010- 11. The Assessee Has Raised The Following Grounds Of Appeal: 1. On The Facts & The Circumstances Of The Case & In Law, The Cit(A) Has Erred In Confirming: I) The Disallowance Made U/S.14A Of The Income Tax Act At Rs.7, 06,985/- As Against Disallowance Of Rs.2, 52,536/- As Computed By The Appellant. The Disallowance Made Of Rs.4, 54,449/- May Please Be Deleted.

For Appellant: Sh. Ruturaj GurjarFor Respondent: Sh. B.K. Bagchi, CIT-DR
Section 14Section 14A

loss from securities trading cannot be treated as speculation loss when gross total income consists mainly of income from capital gain, interest on securities and income from other sources. Therefore, it is submitted that this loss has to be assessed as business loss only. 6.3 The assessee’s submissions

M/S Khandwala Securities Ltd., Mumbai vs. DCIT Cir. 4(3)(1), Mumbai

The appeal is dismissed

ITA 1146/MUM/2020[2009-10]Status: DisposedITAT Mumbai28 Apr 2022AY 2009-10
For Appellant: Shri V.M. Chavda
Section 143(3)Section 254Section 73

business of a company (other than a company whose gross total income consists mainly of income which is chargeable under the heads "Interest on securities", "Income from house property", "Capital gains" and "Income from other sources", or a company the principal business of which is the business of trading

Life Insurance Corporation of India, Mumbai vs. ACIT 3(2)(1), Mumbai

In the result, appeal of the assessee is dismissed

ITA 3403/MUM/2019[2015-16]Status: DisposedITAT Mumbai08 Apr 2022AY 2015-16

Bench: Shri Pramod Kumar, Vice- & Shri Vikas Awasthyआअसं.2908/मुं/2019 ("न.व .2015-16) The Acit 3(2)(1), Room No.674, 6Th Floor, Aaykar Bhavan, M.K.Road, ...... अपीलाथ" /Appellant Mumbai – 400 020 बनाम Vs. Life Insurance Corporation Of India, Central Office, Yogakshema Jeevan Bima Marg, Nariman Point, Mumbai 400 005. Pan: Aaacl-0582-H ..... ""तवाद"/Respondent आअसं. 3403/मुं/2019 ("न. व .2015-16) Life Insurance Corporation Of India, Central Office, Yogakshema Jeevan Bima Marg, Nariman Point, Mumbai 400 005. ...... अपीलाथ" /Appellant Pan: Aaacl-0582-H बनाम Vs. The Acit 3(2)(1), Room No.674, 6Th Floor, Aaykar Bhavan, M.K.Road, ..... ""तवाद"/Respondent Mumbai – 400 02

For Appellant: Shri T. SankarFor Respondent: Shri Farrokh V. Irani
Section 10Section 10(34)Section 115OSection 14ASection 44

Notwithstanding anything to the contrary contained in the provisions of this Act relating to the computation of income chargeable under the head "Interest on securities", "Income from house property", "Capital gains" or "Income from other sources", or in section 199 or in sections 28 to 43B, the profits and gains ... obstinate’ clause which overrides the provisions of the Act relating to computation of income chargeable to tax under the head: (i) Interest on Securities; 19 ITA NO.3403/MUM/2019(A.Y. 2015-16) (ii) Income from House Property; (iii) Capital Gains; (iv) Income from other sources. (v) Profits & Gains of business (Section

ACIT 3(2)(1), Mumbai vs. Life Insurance Corporation of India, Mumbai

In the result, appeal of the assessee is dismissed

ITA 2908/MUM/2019[2015-16]Status: DisposedITAT Mumbai08 Apr 2022AY 2015-16

Bench: Shri Pramod Kumar, Vice- & Shri Vikas Awasthyआअसं.2908/मुं/2019 ("न.व .2015-16) The Acit 3(2)(1), Room No.674, 6Th Floor, Aaykar Bhavan, M.K.Road, ...... अपीलाथ" /Appellant Mumbai – 400 020 बनाम Vs. Life Insurance Corporation Of India, Central Office, Yogakshema Jeevan Bima Marg, Nariman Point, Mumbai 400 005. Pan: Aaacl-0582-H ..... ""तवाद"/Respondent आअसं. 3403/मुं/2019 ("न. व .2015-16) Life Insurance Corporation Of India, Central Office, Yogakshema Jeevan Bima Marg, Nariman Point, Mumbai 400 005. ...... अपीलाथ" /Appellant Pan: Aaacl-0582-H बनाम Vs. The Acit 3(2)(1), Room No.674, 6Th Floor, Aaykar Bhavan, M.K.Road, ..... ""तवाद"/Respondent Mumbai – 400 02

For Appellant: Shri T. SankarFor Respondent: Shri Farrokh V. Irani
Section 10Section 10(34)Section 115OSection 14ASection 44

Notwithstanding anything to the contrary contained in the provisions of this Act relating to the computation of income chargeable under the head "Interest on securities", "Income from house property", "Capital gains" or "Income from other sources", or in section 199 or in sections 28 to 43B, the profits and gains ... obstinate’ clause which overrides the provisions of the Act relating to computation of income chargeable to tax under the head: (i) Interest on Securities; 19 ITA NO.3403/MUM/2019(A.Y. 2015-16) (ii) Income from House Property; (iii) Capital Gains; (iv) Income from other sources. (v) Profits & Gains of business (Section

Income Tax Officer, Bangalore vs. M/S.Dell India Pvt.Ltd., Bangalore

In the result the appeals filed by assessee and revenue for A

ITA 2035/BANG/2016[2014-15]Status: DisposedITAT Bangalore25 Mar 2022AY 2014-15

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

Section 201

mandates the tax deductor to deduct "income-tax" on "any income by way of interest other than income by way of interest on securities". The phrase "any income" and "income-tax thereon" if read harmoniously, it would indicate that the interest which finally partakes the character of income, alone

Dell International Services India Pvt. Ltd., Bangalore vs. ITO, Bangalore

In the result the appeals filed by assessee and revenue for A

ITA 1151/BANG/2015[2012-13]Status: DisposedITAT Bangalore25 Mar 2022AY 2012-13

Bench: Shri. Chandra Poojari & Smt. Beena Pillai

Section 201

mandates the tax deductor to deduct "income-tax" on "any income by way of interest other than income by way of interest on securities". The phrase "any income" and "income-tax thereon" if read harmoniously, it would indicate that the interest which finally partakes the character of income, alone