DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 1(1), MANGALURU, MANGALURU vs. KARNATAKA BANK LTD., MANGALURU

Appeals of the revenue are partly allowed for\nstatistical purposes

VIA).\n(iv) Clause (d) is applicable to Non-banking financial company\nfrom AY 2017-18.\nThe Hon'ble Supreme Court in the case of Catholic Syrian Bank\n(supra) has held that the PBDD allowed under clause (a) of Sec.\n36(1)(viia) refers to ‘rural advances' only. In fact the expression\n“rural branches” finds place in clause

KARNATAKA BANK LTD,MANGALORE vs. ASSISTANT COMMISSIONER OF INCOME TAX, MANGALORE

In the result, the appeal of the revenue for AYs 2016-17 and\n2017-18 are partly allowed for statistical purposes

VIA).\n(iv) Clause (d) is applicable to Non-banking financial company\nfrom AY 2017-18.\nThe Hon'ble Supreme Court in the case of Catholic Syrian Bank\n(supra) has held that the PBDD allowed under clause (a) of Sec.\n36(1)(viia) refers to ‘rural advances' only. In fact the expression\n“rural branches” finds place in clause

M/S VIJAYA BANK ,BANGALORE vs. ADDITIONAL COMMISSIONER OF INCOME TAX LTU , BANGALORE

Accordingly the grounds raised by the revenue is allowed for statistical purposes

Bench: Shri George George K. & Shri Laxmi Prasad Sahum/S. Bank Of Baroda Vs. Addl. Cit, Ltu, (Erstwhile Vijaya Bank) Bmtc Building 7Th Floor, Central Accounts 6Th Block, Koramangala Bengaluru 560095 Dept., 41/2, M.G. Road Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Acit, Circle - 2(1)(1) Vs. M/S. Bank Of Baroda Room No. 561, 5Th Floor (Erstwhile Vijaya Bank) Aayakar Bhavan 7Th Floor, Central Accounts M.K. Road Dept., 41/2, M.G. Road Mumbai 400020 Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Assessee By: Shri Ananthan, Ca& Smt. Lalitha Rameswaran, Ca Revenue By: Shri G. Manoj Kumar, Cit-Dr Date Of Hearing: 29.03.2023 Date Of Pronouncement: 25.04.2023 M/S. Bank Of Baroda

VIA). (iv) Clause (d) is applicable to Non-banking financial company from AY 2017-18. The Hon’ble Supreme Court in the case of Catholic Syrian Bank (supra) has held that the PBDD allowed under clause (a) of Sec. 36(1)(viia) refers to ‘rural advances’ only. In fact the expression “rural branches” finds place in clause (a) only

ADDL/JOINT COMMISSIONER OF INCOME TAX (LTU) , BANGALORE vs. M/S VIJAYA BANK , BANGALORE

Accordingly the grounds raised by the revenue is allowed for statistical purposes

Bench: Shri George George K. & Shri Laxmi Prasad Sahum/S. Bank Of Baroda Vs. Addl. Cit, Ltu, (Erstwhile Vijaya Bank) Bmtc Building 7Th Floor, Central Accounts 6Th Block, Koramangala Bengaluru 560095 Dept., 41/2, M.G. Road Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Acit, Circle - 2(1)(1) Vs. M/S. Bank Of Baroda Room No. 561, 5Th Floor (Erstwhile Vijaya Bank) Aayakar Bhavan 7Th Floor, Central Accounts M.K. Road Dept., 41/2, M.G. Road Mumbai 400020 Bengaluru 560001 Pan – Aaacvo3787 (Appellant) (Respondent) Assessee By: Shri Ananthan, Ca& Smt. Lalitha Rameswaran, Ca Revenue By: Shri G. Manoj Kumar, Cit-Dr Date Of Hearing: 29.03.2023 Date Of Pronouncement: 25.04.2023 M/S. Bank Of Baroda

VIA). (iv) Clause (d) is applicable to Non-banking financial company from AY 2017-18. The Hon’ble Supreme Court in the case of Catholic Syrian Bank (supra) has held that the PBDD allowed under clause (a) of Sec. 36(1)(viia) refers to ‘rural advances’ only. In fact the expression “rural branches” finds place in clause (a) only

THE KARNATAKA BANK LTD,MANGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1), MANGALURU

In the result, the appeal filed by the Revenue is dismissed and the appeal of the assessee is partly allowed

Bench: Shri N.V. Vasudevan & Shri B.R. Baskaranthe Karnataka Bank Ltd. Dcit, Circle - 2(1) Head Office, Mahaveera Circle Mangalore Vs. Kankanady Mangalore 575002 Pan – Aabct5589K Appellant Respondent Dcit, Circle – 2(1) The Karnataka Bank Ltd. Mangalore Head Office, Mahaveera Circle Vs. Kankanady Mangalore 575002 Pan – Aabct5589K Appellant Respondent Assessee By: Shri S. Ananthan, Ca & Smt. Lalitha Rameswaran, Ca Revenue By: Shri Mudavathu Harish Chandra Naik, Ca Date Of Hearing: 22.03.2022 Date Of Pronouncement: 26.05.2022 O R D E R Per: B.R. Baskaran, A.M. These Cross Appeals Are Directed Against The Order Dated 27-03-2018 Passed By Ld Cit(A), Mangaluru & They Relate To The Assessment Year 2014-15. 2. The Assessee Is A Banking Company Carrying On Banking Business. The Karnataka Bank Ltd.

depreciation only for income tax purposes, both the assessee and the assessing officer shall ensure that the profit/loss arising on sale of these investments should be ascertained by considering the value of investments as per income tax records and not as per books of account. 5. The next issue contested by the revenue relates to the disallowance made

M/S. CORPORATION BANK,MANGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE- 2(1), MANGALURU

Bench: Shri George George K & Ms. Padmavathy S & Ita No.1680/Bang/2018 Assessment Year : 2015-16 & 2014-15

via) of the Act. However, the Ld CIT(A) expressed the view that the PBDD allowed u/s 36(1)(viia) of the Act is applicable to both Rural and non-Rural debts. Accordingly, he held that the entire amount of bad debts written off (both rural and non-rural) should be first adjusted against the provision allowed u/s 36(1

VIJAYA BANK,BANGALORE vs. ADDL.C.I.T., BANGALORE

In the result the appeal by the Assessee is allowed

Bench: Shri N.V. Vasudevan & Shri Jason P. Boazassessment Year : 2008-09

via) in a sum of Rs. 1,10,94,360. The assessing officer did not allow the claim for deduction of debts amounting to Rs. 38,28,836 actually written off. The CIT(A) rejected the assessee’s claim and upheld the order of Assessing Officer and the ITAT held that deduction under section 36(1)(vii) was allowable independently

JCIT, BANGALORE vs. M/S VIJAYA BANK, BANGALORE

In the result the appeal by the Assessee is allowed

Bench: Shri N.V. Vasudevan & Shri Jason P. Boazassessment Year : 2008-09

via) in a sum of Rs. 1,10,94,360. The assessing officer did not allow the claim for deduction of debts amounting to Rs. 38,28,836 actually written off. The CIT(A) rejected the assessee’s claim and upheld the order of Assessing Officer and the ITAT held that deduction under section 36(1)(vii) was allowable independently

JCIT, BANGALORE vs. M/S VIJAYA BANK, BANGALORE

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

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Raojoint Commissioner Of Income-Tax, Ltu, Bangalore. … Appellant Vs. M/S. Vijaya Bank, Head Office, Central Accounts Dept. 41/2, Mg Road, Bangalre-560001. … Respondent Pa No.Aaacv 4791 J & M/S. Vijaya Bank, Ho, Central Accounts Dept. 41/2, M.G.Road, Bangalore. … Appellant Vs. Addl. Commissioner Of Income-Tax, Ltu, Bangalore. … Respondent Revenue By : Shri P.Chandrashekar, Cit(Dr) Assessee By : Shri S.Ananthan, Ca & Smt.Lalitha Ramaswamy, Ca Date Of Hearing : 07/06/2016 Date Of Pronouncement : 22/07/2016 O R D E R Per Inturi Rama Rao, Am : These Are Cross Appeals Filed By The Assessee-Bank As Well As The Revenue Directed Against The Order Of The Cit(A), Ltu, Bangalore, Dated 28/11/2013 For The Assessment Year 2009-10. Ita Nos.318 & 331/Bang/2014 Page 2 Of 25 2. Briefly, Facts Of The Case Are That The Assessee Is A Nationalized Bank Engaged In The Business Of Banking. It Filed Return Of Income For The Assessment Year 2009-10 On 29/9/2009 Declaring A Total Income Of Rs.540,24,85,305/-. Against The Said Return Of Income, Assessment Was Completed By The Addl. Cit (Ltu), Bangalore, U/S 143(3) Of The Income-Tax Act, 1961 [Hereinafter Referred To As 'The Act' For Short] Vide Order Dated 30/08/2011 At A Total Income Of Rs.1205,99,81,409/-. While Doing So, The Ao Made The Following Disallowances:

depreciation of Rs. 151,48,15,234/- on HTM category of securities, as this was not considered as revenue expenditure while finalizing accounts and was claimed only in the computation income. 3. The Commissioner (Appeals) erred in allowing the assessee's claim of mark to market loss on derivatives of Rs.111,89,71,243/-, as this expenditure was not considered

VIJAYA BANK,BANGALORE vs. ADDL..C.I.T., BANGALORE

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

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Raojoint Commissioner Of Income-Tax, Ltu, Bangalore. … Appellant Vs. M/S. Vijaya Bank, Head Office, Central Accounts Dept. 41/2, Mg Road, Bangalre-560001. … Respondent Pa No.Aaacv 4791 J & M/S. Vijaya Bank, Ho, Central Accounts Dept. 41/2, M.G.Road, Bangalore. … Appellant Vs. Addl. Commissioner Of Income-Tax, Ltu, Bangalore. … Respondent Revenue By : Shri P.Chandrashekar, Cit(Dr) Assessee By : Shri S.Ananthan, Ca & Smt.Lalitha Ramaswamy, Ca Date Of Hearing : 07/06/2016 Date Of Pronouncement : 22/07/2016 O R D E R Per Inturi Rama Rao, Am : These Are Cross Appeals Filed By The Assessee-Bank As Well As The Revenue Directed Against The Order Of The Cit(A), Ltu, Bangalore, Dated 28/11/2013 For The Assessment Year 2009-10. Ita Nos.318 & 331/Bang/2014 Page 2 Of 25 2. Briefly, Facts Of The Case Are That The Assessee Is A Nationalized Bank Engaged In The Business Of Banking. It Filed Return Of Income For The Assessment Year 2009-10 On 29/9/2009 Declaring A Total Income Of Rs.540,24,85,305/-. Against The Said Return Of Income, Assessment Was Completed By The Addl. Cit (Ltu), Bangalore, U/S 143(3) Of The Income-Tax Act, 1961 [Hereinafter Referred To As 'The Act' For Short] Vide Order Dated 30/08/2011 At A Total Income Of Rs.1205,99,81,409/-. While Doing So, The Ao Made The Following Disallowances:

depreciation of Rs. 151,48,15,234/- on HTM category of securities, as this was not considered as revenue expenditure while finalizing accounts and was claimed only in the computation income. 3. The Commissioner (Appeals) erred in allowing the assessee's claim of mark to market loss on derivatives of Rs.111,89,71,243/-, as this expenditure was not considered

CANARA BANK,BANGALORE vs. ADDL.C.I.T., BANGALORE

In the result, appeal by the revenue is partly allowed

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

depreciation on assets leased to Kedia Group of companies, the ld. CIT(A) held that the AO had not complied with the directions of this Tribunal, non-compliance of the directions of this Tribunal amounts to violation of principles of natural justice. However, keeping in view the fact that for earlier assessment year, the issue was remitted back

JCIT, BANGALORE vs. M/S CANARA BANK, BANGALORE

In the result, appeal by the revenue is partly allowed

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

depreciation on assets leased to Kedia Group of companies, the ld. CIT(A) held that the AO had not complied with the directions of this Tribunal, non-compliance of the directions of this Tribunal amounts to violation of principles of natural justice. However, keeping in view the fact that for earlier assessment year, the issue was remitted back

CANARA BANK,BANGALORE vs. ADDL. C.I.T., BANGALORE

In the result, appeal by the revenue is partly allowed

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

depreciation on assets leased to Kedia Group of companies, the ld. CIT(A) held that the AO had not complied with the directions of this Tribunal, non-compliance of the directions of this Tribunal amounts to violation of principles of natural justice. However, keeping in view the fact that for earlier assessment year, the issue was remitted back

M/S. CANARA BANK,BANGALORE vs. ACIT, BANGALORE

In the result, appeal by the revenue is partly allowed

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

depreciation on assets leased to Kedia Group of companies, the ld. CIT(A) held that the AO had not complied with the directions of this Tribunal, non-compliance of the directions of this Tribunal amounts to violation of principles of natural justice. However, keeping in view the fact that for earlier assessment year, the issue was remitted back

ADDL.CIT, BANGALORE vs. M/S CANARA BANK, BANGALORE

In the result, appeal by the revenue is partly allowed

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

depreciation on assets leased to Kedia Group of companies, the ld. CIT(A) held that the AO had not complied with the directions of this Tribunal, non-compliance of the directions of this Tribunal amounts to violation of principles of natural justice. However, keeping in view the fact that for earlier assessment year, the issue was remitted back

JCIT, BANGALORE vs. M/S CANARA BANK, BANGALORE

In the result, appeal by the revenue is partly allowed

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

depreciation on assets leased to Kedia Group of companies, the ld. CIT(A) held that the AO had not complied with the directions of this Tribunal, non-compliance of the directions of this Tribunal amounts to violation of principles of natural justice. However, keeping in view the fact that for earlier assessment year, the issue was remitted back

ADDL.CI.T., BANGALORE vs. M/S CANARA BANK, BANGALORE

In the result, appeal by the revenue is partly allowed

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

depreciation on assets leased to Kedia Group of companies, the ld. CIT(A) held that the AO had not complied with the directions of this Tribunal, non-compliance of the directions of this Tribunal amounts to violation of principles of natural justice. However, keeping in view the fact that for earlier assessment year, the issue was remitted back

CANARA BANK,BANGALORE vs. JCIT, BANGALORE

In the result, appeal by the revenue is partly allowed

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

depreciation on assets leased to Kedia Group of companies, the ld. CIT(A) held that the AO had not complied with the directions of this Tribunal, non-compliance of the directions of this Tribunal amounts to violation of principles of natural justice. However, keeping in view the fact that for earlier assessment year, the issue was remitted back