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

disallowance of Rs.192.02 crores. 7.5 The Ld A.R submitted that the Ld CIT(A) has rendered his decision by following his decision rendered in AY 2013-14 and earlier years. He submitted that Finance Act, 2013 has inserted “Explanation 2” in sec. 36(1)(vii) of the Act and the same reads as under:- “Explanation 2 – For the removal

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

disallowance of Rs.192.02 crores. 7.5 The Ld A.R submitted that the Ld CIT(A) has rendered his decision by following his decision rendered in AY 2013-14 and earlier years. He submitted that Finance Act, 2013 has inserted “Explanation 2” in sec. 36(1)(vii) of the Act and the same reads as under:- “Explanation 2 – For the removal

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

disallowed a sum of Rs.1387,81,80,315/- out of total claim of Rs.1695,59,52,309/-. The assessee bank contended before the learned Commissioner (Appeals) that there is no requirement in Section 36(1)(viia) that the provision should be in relation to rural advances. Further, it was contended that the reliance placed by the learned Assessing Officer

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

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

disallowance u/s\n36(1)(vii) of the Act of Rs.1073,95,04,388/- being the bad debts\nwritten off by the non-rural branches of the assessee's bank.\n9.\nFacts of the case are that The assessee claimed a sum of\nRs.1073.95 crore as bad debts u/s 36(1)(vii) of the Act related to\nnon-rural branches

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

disallowance u/s 36(1)(vii) of the Act of Rs.1073,95,04,388/- being the bad debts written off by the non-rural branches of the assessee’s bank. 9. Facts of the case are that The assessee claimed a sum of Rs.1073.95 crore as bad debts u/s 36(1 )(vii) of the Act related to non-rural branches

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

CANARA BANK,BENGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1)(1), BANGALORE, BENGALURU

In the result, revenue’s appeal in ITA No

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

disallows certain expenditures incurred to earn exempt income from being deducted from other incomes which is includable in the total income for the purposes of chargeability to the Lax. It i4 equally well settled that expenditure is a pay out. In order to attract applicability of section 14,4 of the Act, there

DEPUTY COMMISSIONER OF INCOME TAX CIRCLE-2(1)(1), BENGALURU, BENGALURU vs. CANARA BANK, BENGALURU

In the result, revenue’s appeal in ITA No

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

disallows certain expenditures incurred to earn exempt income from being deducted from other incomes which is includable in the total income for the purposes of chargeability to the Lax. It i4 equally well settled that expenditure is a pay out. In order to attract applicability of section 14,4 of the Act, there

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 of such amount paid beyond the due date, as it is in contravention of section 36(1)(va) of the Act, while computing the total income in the return of income. Instead of doing that, the assessee has claimed deduction of the amount under section 36(1)(va) of the Act. Thus, in our considered opinion, the adjustment clearly

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

Appeals of the revenue are partly allowed for statistical purposes

disallowance u/s. 14A r.w. Rule 8D.\n\n13. Ground No.3 regarding deduction 36(1)(vii) is also common for both the years. The brief facts for AY 2016-17 are that while computing the taxable income, the Appellant bank had claimed a deduction of Rs. 303,86,90,303/- u/s 36(1)(vii), in respect of non-rural debts written

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 u/s. 14A\nr.w. Rule 8D.\n13.\nGround No.3 regarding deduction 36(1)(vii) is also common for\nboth the years. The brief facts for AY 2016-17 are that while\ncomputing the taxable income, the Appellant bank had claimed a\ndeduction of Rs. 303,86,90,303/- u/s 36(1)(vii), in respect of non-rural\ndebts written

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

disallowance u/s. 14A\nr.w. Rule 8D.\n13. Ground No.3 regarding deduction 36(1)(vii) is also common for\nboth the years. The brief facts for AY 2016-17 are that while\ncomputing the taxable income, the Appellant bank had claimed a\ndeduction of Rs. 303,86,90,303/- u/s 36(1)(vii), in respect of non-rural\ndebts written

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

disallowance u/s. 14A\nr.w. Rule 8D.\n13. Ground No.3 regarding deduction 36(1)(vii) is also common for\nboth the years. The brief facts for AY 2016-17 are that while\ncomputing the taxable income, the Appellant bank had claimed a\ndeduction of Rs. 303,86,90,303/- u/s 36(1)(vii), in respect of non-rural\ndebts written

M/S. BANGALORE PHARMACEUTICAL AND RESEARCH LABORATORY PRIVATE LIMITED,BANGALORE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, CIRCLE-1(1)(2), BANGALORE

In the result, the appeal by the assessee is dismissed

Bench: Shri George George K. & Shri Laxmi Prasad Sahuassessment Year : 2018-19

iv) on the following grounds: a) Clause 20(b) of Form 3CD is not aligned with Section 36(1)(va) b) Clear indications by the auditor in his report in Form 3CA (Pages 156-157 of the paper book Volume 1) that no disallowance

M/S. NANDI HOSPITALITY SERVICES PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(1)(1), BANGALORE

In the result, all the three appeals filed by the assessee are dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

iv), and its liability to deposit amounts received by it or deducted by it (Section 36(1)(va)) is, thus crucial. The former forms part of the employers' income, and the later retains its character as an income (albeit deemed), by virtue of Section 2(24)(x) - unless the conditions spelt by Explanation to Section 36(1)(va) are satisfied

M/S. NANDI HOSPITALITY SERVICES PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(1)(1), BANGALORE

In the result, all the three appeals filed by the assessee are dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

iv), and its liability to deposit amounts received by it or deducted by it (Section 36(1)(va)) is, thus crucial. The former forms part of the employers' income, and the later retains its character as an income (albeit deemed), by virtue of Section 2(24)(x) - unless the conditions spelt by Explanation to Section 36(1)(va) are satisfied

M/S. NANDI HOSPITALITY SERVICES PRIVATE LIMITED,BENGALURU vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-3(1)(1), BANGALORE

In the result, all the three appeals filed by the assessee are dismissed

Bench: Shri Chandra Poojari & Smt. Beena Pillai

iv), and its liability to deposit amounts received by it or deducted by it (Section 36(1)(va)) is, thus crucial. The former forms part of the employers' income, and the later retains its character as an income (albeit deemed), by virtue of Section 2(24)(x) - unless the conditions spelt by Explanation to Section 36(1)(va) are satisfied

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 Rs.192.02 crores.” 7.5 The Ld A.R submitted that the Ld CIT(A) has rendered his decision by following his decision rendered in AY 2013-14 and earlier years. He submitted that Finance Act, 2013 has inserted “Explanation 2” in sec. 36(1)(vii) of the Act and the same reads as under:- “Explanation 2 – For the removal