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

VIA and an amount not exceeding 10 per cent of the aggregate average advances made by the rural branches of such bank computed in the prescribed manner are allowed as deduction. It is clear from the said provision that the distinction has been made between the branches situated in the rural areas and the branches situated outside the rural areas

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

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

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

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

68,82,781 deduction is claimed u/s.36(1)(viia) @ 10% of the Bad & Doubtful Debts in the AY 2004-05. ITA Nos. 578 & 653/Bang/2012 Page 17 of 49 18. The AO was of the view that just as how the Assessee has adjusted the PBDD in respect of rural advances, it ought to have adjusted PBDD in respect

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

68,82,781 deduction is claimed u/s.36(1)(viia) @ 10% of the Bad & Doubtful Debts in the AY 2004-05. ITA Nos. 578 & 653/Bang/2012 Page 17 of 49 18. The AO was of the view that just as how the Assessee has adjusted the PBDD in respect of rural advances, it ought to have adjusted PBDD in respect

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

VIA is alone to be considered for the purpose of calculating amount of deduction under the said provision. The reliance placed by the learned counsel for the assessee-bank on the decision in the case of Kerala State Industrial Development Corporation (96 taxman 641) and Bihar State Financial Corporation (142 ITR 518) is misplaced. Those decisions were rendered

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

VIA is alone to be considered for the purpose of calculating amount of deduction under the said provision. The reliance placed by the learned counsel for the assessee-bank on the decision in the case of Kerala State Industrial Development Corporation (96 taxman 641) and Bihar State Financial Corporation (142 ITR 518) is misplaced. Those decisions were rendered

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

VIA is alone to be considered for the purpose of calculating amount of deduction under the said provision. The reliance placed by the learned counsel for the assessee-bank on the decision in the case of Kerala State Industrial Development Corporation (96 taxman 641) and Bihar State Financial Corporation (142 ITR 518) is misplaced. Those decisions were rendered

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

VIA is alone to be considered for the purpose of calculating amount of deduction under the said provision. The reliance placed by the learned counsel for the assessee-bank on the decision in the case of Kerala State Industrial Development Corporation (96 taxman 641) and Bihar State Financial Corporation (142 ITR 518) is misplaced. Those decisions were rendered

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

VIA is alone to be considered for the purpose of calculating amount of deduction under the said provision. The reliance placed by the learned counsel for the assessee-bank on the decision in the case of Kerala State Industrial Development Corporation (96 taxman 641) and Bihar State Financial Corporation (142 ITR 518) is misplaced. Those decisions were rendered

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

VIA is alone to be considered for the purpose of calculating amount of deduction under the said provision. The reliance placed by the learned counsel for the assessee-bank on the decision in the case of Kerala State Industrial Development Corporation (96 taxman 641) and Bihar State Financial Corporation (142 ITR 518) is misplaced. Those decisions were rendered

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

VIA is alone to be considered for the purpose of calculating amount of deduction under the said provision. The reliance placed by the learned counsel for the assessee-bank on the decision in the case of Kerala State Industrial Development Corporation (96 taxman 641) and Bihar State Financial Corporation (142 ITR 518) is misplaced. Those decisions were rendered

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

VIA is alone to be considered for the purpose of calculating amount of deduction under the said provision. The reliance placed by the learned counsel for the assessee-bank on the decision in the case of Kerala State Industrial Development Corporation (96 taxman 641) and Bihar State Financial Corporation (142 ITR 518) is misplaced. Those decisions were rendered

M/S. LIFE INSURANCE CORPORATION OF INDIA,THIRTHAHALLI vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

68,049 2015-16 40,020 14,400 1,460 588 - - 56,468 2016-17 1,30,588 31,320 666 156 9,116 2,275 1,74,121 Shivamogga: Payment to HP In la Sales Cash Medical Benefit u/s Pvt. Ltd. an MDC Projects Total 192 u s 194J# TDS Interest u/ s TDS Interest u/ s deductible

M/S. LIFE INSURANCE CORPORATION OF INDIA,DAVANGERE vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

68,049 2015-16 40,020 14,400 1,460 588 - - 56,468 2016-17 1,30,588 31,320 666 156 9,116 2,275 1,74,121 Shivamogga: Payment to HP In la Sales Cash Medical Benefit u/s Pvt. Ltd. an MDC Projects Total 192 u s 194J# TDS Interest u/ s TDS Interest u/ s deductible

M/S. LIFE INSURANCE CORPORATION OF INDIA,THIRTHAHALLI vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

68,049 2015-16 40,020 14,400 1,460 588 - - 56,468 2016-17 1,30,588 31,320 666 156 9,116 2,275 1,74,121 Shivamogga: Payment to HP In la Sales Cash Medical Benefit u/s Pvt. Ltd. an MDC Projects Total 192 u s 194J# TDS Interest u/ s TDS Interest u/ s deductible

M/S. LIFE INSURANCE CORPORATION OF INDIA,THIRTHAHALLI vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

68,049 2015-16 40,020 14,400 1,460 588 - - 56,468 2016-17 1,30,588 31,320 666 156 9,116 2,275 1,74,121 Shivamogga: Payment to HP In la Sales Cash Medical Benefit u/s Pvt. Ltd. an MDC Projects Total 192 u s 194J# TDS Interest u/ s TDS Interest u/ s deductible

M/S. LIFE INSURANCE CORPORATION OF INDIA,DAVANGERE vs. THE INCOME TAX OFFICER (TDS) WARD, DAVANGERE

In the result, the appeals filed by the assessee stands allowed for assessment years 2011-12 to 2014-15 on the legal issue and the appeals for assessment years 2015-

Bench: Shri B.R Baskaran & Smt. Beena Pillai

68,049 2015-16 40,020 14,400 1,460 588 - - 56,468 2016-17 1,30,588 31,320 666 156 9,116 2,275 1,74,121 Shivamogga: Payment to HP In la Sales Cash Medical Benefit u/s Pvt. Ltd. an MDC Projects Total 192 u s 194J# TDS Interest u/ s TDS Interest u/ s deductible