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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

Sukesini Kumili, Hyderabad vs. ITO, Ward-15(1), Hyderabad

In the result, the appeals of the assessee in ITA no

ITA 1539/HYD/2025[2016-17]Status: DisposedITAT Hyderabad16 Jan 2026AY 2016-17

Bench: Shri Vijay Pal Rao, Vice- & Shri Madhusudan Sawdiaappeal In Ita Nos. Assessee Revenue A.Ys 1536 To 1539/ Hyd/2025 Sukesini Kumili, Hyderabad Pan:Ckmpk5466J Income Tax Officer Ward 15(1), Hyderabad 2015-16 & 2016-17 निर्धारिती द्वारा /Assessee By: Advocate Shri S. Rama Rao राजस्व द्वारा / Revenue By:: || Shri Madhukar Aves, Sr. Dr सुनवाई की तारीख/Date Of Hearing: | 07/01/2016 घोषणा की तारीख / Pronouncement: 16/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: These Four Appeals Are Filed By Smt. Sukesini Kumili ("The Assessee") Feeling Aggrieved By The Separate Orders Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi (“Ld. Cit(A)”) For The A.Ys 2015-16 & 2016-17, All Dated 16.07.2025. Since Inter-Related Issues Are Involved In All These Four Appeals, For The Sake Of Convenience, These Were Heard Together & Are Being Disposed Of By This Common Consolidated Order.

For Appellant: Advocate Shri S. Rama Rao
Section 115BSection 144Section 147Section 148Section 148ASection 149Section 151A(1)Section 153

with a banking company BANK OF BARODA 29 TRANSACTION AMOUNT 2,23,96,463 TDS194A TDS Statement Interest other than interest on securities (Section 194A) ANDHRA BANK, SITAPHALMANDI BR. 5 AMOUNT PAID OR CREDITED 31,890 7. 3. On the basis of above information, which reveals that the income chargeable

ITO(TDS)-2(2)(1), Mumbai vs. Sashwat Energy Private Limited, Mumbai

In the result, the CO is allowed for statistical purposes

ITA 4279/MUM/2025[2021-22]Status: DisposedITAT Mumbai13 Jan 2026AY 2021-22

Bench: Shri Sandeep Gosain & Shri Prabhash Shankarincome Tax Officer (Tds) – V/S. Sashwat Energy Private 2(2)(1) बनाम Limited, 3Rd Floor, Mtnl Building, 10Th Floor, Universal Cumballa Hill, Mumbai – Majestic Lokhande Marg, 400 026, Maharashtra Chembur West, Mumbai – 400 043, Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Mums95080G Appellant/अपीलार्थी .. Respondent/प्रतिवादी प्रत्याक्षेपसं./C.O. No.273/Mum/2025 (Arising Out Of Ita No. 4279/Mum/2025) (A.Y. 2021-22) Sashwat Energy Private V/S. Income Tax Officer (Tds) – Limited, बनाम 2(2)(1), 3Rd Floor, Mtnl 10Th Floor, Universal Majestic Building, Cumballa Hill, Lokhande Marg, Chembur Mumbai – 400 026, West, Mumbai – 400 043, Maharashtra Maharashtra स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Mums95080G Appellant/अपीलाथी .. Respondent/प्रतिवादी

For Appellant: Ms Kinjal Bhuta,ARFor Respondent: Shri Surendra Mohan, (Sr. DR)
Section 133ASection 194ASection 194JSection 200Section 201Section 201(1)Section 40Section 40a

section 194A, an assessee who is responsible for paying to a resident any income by way of interest other than interest on securities, shall deduct income- tax thereon at the prescribed rates at the time of payment or at the time of credit of such income to the account