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

disallowance of bad debts written off under Section 36(1)(vii) of the Act. The facts are that the assessee

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

In the result, the appeal of the assessee is partly allowed for statistical purposes and the revenue’s appeal is dismissed

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K., Judciial Member Assessment Year : 2015-16

disallowing the claim of Rs. 218,08,80,715/- of the appellant bank u/s 36(1)(vii) being the bad debts written off by the non-rural branches of the Appellant bank. 2.1. The learned CIT(A) failed to appreciate the fact that the non- rural debts are not controlled by the proviso to Section

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

In the result, the appeal of the assessee is partly allowed for statistical purposes and the revenue’s appeal is dismissed

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K., Judciial Member Assessment Year : 2015-16

disallowing the claim of Rs. 218,08,80,715/- of the appellant bank u/s 36(1)(vii) being the bad debts written off by the non-rural branches of the Appellant bank. 2.1. The learned CIT(A) failed to appreciate the fact that the non- rural debts are not controlled by the proviso to Section

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

Appeals of the revenue are partly allowed for statistical purposes

sections": [ "14A", "115JB", "36(1)(vii)", "36(1)(viia)", "36(2)(v)" ], "issues": "Disallowance of expenses under Section 14A; deduction

M/S. RMZ HOTELS PRIVATE LIMITED,BANGALORE vs. NATIONAL E-ASSESSMENT CENTRE, DELHI

In the result, the appeal of the assessee is allowed

Bench: Shri Chandra Poojariassessment Year: 2018-19

36(1)(iii) of the Act, but under section 57(iii). The Tribunal disallowed interest under both, i.e., section 36

M/S SYNDICATE BANK,MANIPAL vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 1, UDUPI

In the result, appeal of the revenue in ITA No

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment Year: 2015-16

section 36(1)(vii) which requires adjustment of bad debts against provision allowed u/s 36(1)(viia) would apply to non-rural advances also) is hereby set aside. Hence, we direct the A.O. to delete the disallowance

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

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

36(1)(viia)", "Section 115JB", "Section 43D"], "issues": "Disallowance under Section 14A; deduction for bad debts and provision for bad and doubtful

M/S. CANARA BANK (ERSTWHILE SYNDICATE BANK),BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-2(1)(1), BANGALORE

In the result, the appeals are partly allowed for statistical purposes

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

section 36(1)(vii) which requires adjustment of bad debts against provision allowed u/s 36(1)(viia) would apply to non-rural advances also) is hereby set aside. Hence, we direct the A.O. to delete the disallowance

M/S. CANARA BANK (ERSTWHILE SYNDICATE BANK),BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, LTU, CIRCLE-2, BANGALORE

In the result, the appeals are partly allowed for statistical purposes

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

section 36(1)(vii) which requires adjustment of bad debts against provision allowed u/s 36(1)(viia) would apply to non-rural advances also) is hereby set aside. Hence, we direct the A.O. to delete the disallowance

M/S. CANARA BANK (ERSTWHILE SYNDICATE BANK),BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-2(1)(1), BANGALORE

In the result, the appeals are partly allowed for statistical purposes

Bench: Shri George George K. & Shri Laxmi Prasad Sahu

section 36(1)(vii) which requires adjustment of bad debts against provision allowed u/s 36(1)(viia) would apply to non-rural advances also) is hereby set aside. Hence, we direct the A.O. to delete the disallowance

GLOBAL SECURITY SERVICES ,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-4(3)(1) , BANGALORE

In the result, the appeal of the assessee is dismissed

Bench: Shri Laxmi Prasad Sahu & Shri Keshav Dubeyassessment Year : 2018-19

disallowed said payment made by assessee under section 36(1)(va) by passing intimation order under section 143(1)(a)(iv). It was noted

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

disallowance under Section 14A, deduction for bad debts under Section 36(1)(vii) and 36(1)(viia), and additions to book

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

sections": [ "14A", "115JB", "36(1)(vii)", "36(1)(viia)", "36(2)(v)" ], "issues": "The main issues involved were the disallowance

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1), MANGALORE vs. THE KARNATAKA BANK LIMITED, MANGALORE

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

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment Year: 2020-21

section 115TCA for AY 2020-21. The assessee submitted that this loss is a share of administrative expenses incurred by the securitization trust in recovering the bad debts, which was passed on to the assessee bank. The ld. AO disallowed the claim by noting that the assessee had been claiming deduction u/s 36

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

In the result, appeal of the revenue is partly allowed for statistical\npurposes

sections": [ "14A", "8D", "36(1)(vii)", "36(2)(v)", "115TCA" ], "issues": "The main issues are regarding the disallowance of expenses

M/S. ADVAITH MOTORS PRIVATE LIMITED ,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), BENGALURU

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

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2020-21

disallowance u/s. 36(1)(va) which is not permissible. The employer’s contribution is covered u/s. 43B(b) of the Act and employees’ contribution is covered u/s. 36(1)(va) of the Act. Section

CENTURY SHELTORS,BANGALORE vs. ACIT, CIRCLE-2(2), BANGALORE

In the result, the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Shri Anikesh Banerjee

disallowed under section 36(1)(iii). Section 40 is not a standalone section, it has to be read with section

M/S. CENTURY SILICON CITY,BANGALORE vs. DCIT, CIRCLE-1(2)(1, BANGALORE

In the result, the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Shri Anikesh Banerjee

disallowed under section 36(1)(iii). Section 40 is not a standalone section, it has to be read with section

M/S. CENTURY SILICON CITY,BANGALORE vs. DCIT, CIRCLE-1(2)(1, BANGALORE

In the result, the appeals of the assessees are allowed

Bench: Shri Chandra Poojari & Shri Anikesh Banerjee

disallowed under section 36(1)(iii). Section 40 is not a standalone section, it has to be read with section