BharatTax.net
SearchITATHigh CourtsSupreme CourtPhrasesAI ResearchHistory

Filters

BharatTax.net

Free search engine for ITAT (Income Tax Appellate Tribunal) judgments across all 28 benches in India.

Quick Links

  • Search Judgments
  • Browse by Bench
  • Recent Judgments

About

BharatTax provides free access to Income Tax Appellate Tribunal orders for legal research and reference.

© 2026 BharatTax.net. All rights reserved.

28 results for “transfer pricing”+ Section 36(1)(viia)clear

Sorted by relevance

Mumbai136Delhi49Chandigarh48Chennai34Bangalore28Pune10Hyderabad10Cochin9Jaipur9Surat8Indore7Cuttack7Nagpur4Kolkata3Rajkot3Lucknow2Ahmedabad2Allahabad1Amritsar1Raipur1Karnataka1

Key Topics

Section 36(1)(viia)78Addition to Income26Section 143(3)25Disallowance25Deduction22Depreciation19Section 36(1)(vii)14Section 115J13Section 14A13

CANARA BANK,BANGALORE vs. JCIT, BANGALORE

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

ITA 931/BANG/2016[2011-12]Status: DisposedITAT Bangalore15 Sept 2017AY 2011-12

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri G.Sarangan, Senior Advocate and Shri S.Ananthan, CAFor Respondent: Shri G.R. Reddy, CIT(DR)
Section 143(3)Section 36(1)(vii)

36(1)(viia). At the same time, alternative claim of the assessee that it is to be allowed u/s 37(1), in our view, is acceptable. On a perusal of the assessment order and the facts and materials available on record, it is quite evident that the amount was waived at the direction of the State Govt. Department

J.C.I.T vs. M/S CANARA BANK,

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

Showing 1–20 of 28 · Page 1 of 2

Section 35D8
Section 143(2)8
Business Income7
ITA 1035/BANG/2013[2009-10]Status: DisposedITAT Bangalore15 Sept 2017AY 2009-10

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri G.Sarangan, Senior Advocate and Shri S.Ananthan, CAFor Respondent: Shri G.R. Reddy, CIT(DR)
Section 143(3)Section 36(1)(vii)

36(1)(viia). At the same time, alternative claim of the assessee that it is to be allowed u/s 37(1), in our view, is acceptable. On a perusal of the assessment order and the facts and materials available on record, it is quite evident that the amount was waived at the direction of the State Govt. Department

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

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

ITA 979/BANG/2013[2009-10]Status: DisposedITAT Bangalore15 Sept 2017AY 2009-10

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri G.Sarangan, Senior Advocate and Shri S.Ananthan, CAFor Respondent: Shri G.R. Reddy, CIT(DR)
Section 143(3)Section 36(1)(vii)

36(1)(viia). At the same time, alternative claim of the assessee that it is to be allowed u/s 37(1), in our view, is acceptable. On a perusal of the assessment order and the facts and materials available on record, it is quite evident that the amount was waived at the direction of the State Govt. Department

JOINT COMMISSIONER OF INCOME TAX,, BANGALORE vs. M/S CANARA BANK, BANGALORE

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

ITA 1440/BANG/2014[2010-11]Status: DisposedITAT Bangalore15 Sept 2017AY 2010-11

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri G.Sarangan, Senior Advocate and Shri S.Ananthan, CAFor Respondent: Shri G.R. Reddy, CIT(DR)
Section 143(3)Section 36(1)(vii)

36(1)(viia). At the same time, alternative claim of the assessee that it is to be allowed u/s 37(1), in our view, is acceptable. On a perusal of the assessment order and the facts and materials available on record, it is quite evident that the amount was waived at the direction of the State Govt. Department

CANARA BANK,BANGALORE vs. JCIT, BANGALORE

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

ITA 1493/BANG/2014[2010-11]Status: DisposedITAT Bangalore15 Sept 2017AY 2010-11

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri G.Sarangan, Senior Advocate and Shri S.Ananthan, CAFor Respondent: Shri G.R. Reddy, CIT(DR)
Section 143(3)Section 36(1)(vii)

36(1)(viia). At the same time, alternative claim of the assessee that it is to be allowed u/s 37(1), in our view, is acceptable. On a perusal of the assessment order and the facts and materials available on record, it is quite evident that the amount was waived at the direction of the State Govt. Department

ACIT, MANGALORE vs. M/S CORPORATION BANK, MANGALORE

In the result, appeal of the revenue stands dismissed

ITA 1264/BANG/2013[2011-12]Status: DisposedITAT Bangalore11 Mar 2015AY 2011-12

Bench: Shri Rajpal Yadav & Shri Abraham P George

For Appellant: Shri S. Ananthan, CAFor Respondent: Dr. P.K.Srihari, Addl.CIT
Section 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viiia)

Transfer of Undertakings) Act, 1980, or any other bank being a bank included in the Second Schedule to the Reserve Bank of India Act, 1934; (iii) "public financial institution" shall have the meaning assigned to it in section 4A of the Companies Act, 1956 (1 of 1956); (iv) "State financial corporation" means a financial corporation established under section

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

In the result the appeal by the Assessee is allowed

ITA 653/BANG/2012[2008-09]Status: DisposedITAT Bangalore27 Feb 2015AY 2008-09

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

For Appellant: Shri S.Ananthan and Smt.Lalitha Rameswaran, CAsFor Respondent: Shri O.P.Yadav, CIT-III (DR)
Section 36(1)(viia)

price whichever is lower and consequent deduction allowed. ITA Nos. 578 & 653/Bang/2012 Page 28 of 49 29. The assessee claimed deduction of a sum of Rs.171,29,30,664 in respect of Diminution in the value of Investments held by the Assessee in the “Held to Maturity” (HTM) category of Investments. According to the Assessing Officer

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

In the result the appeal by the Assessee is allowed

ITA 578/BANG/2012[2008-09]Status: DisposedITAT Bangalore27 Feb 2015AY 2008-09

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

For Appellant: Shri S.Ananthan and Smt.Lalitha Rameswaran, CAsFor Respondent: Shri O.P.Yadav, CIT-III (DR)
Section 36(1)(viia)

price whichever is lower and consequent deduction allowed. ITA Nos. 578 & 653/Bang/2012 Page 28 of 49 29. The assessee claimed deduction of a sum of Rs.171,29,30,664 in respect of Diminution in the value of Investments held by the Assessee in the “Held to Maturity” (HTM) category of Investments. According to the Assessing Officer

CANARA BANK,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, LTU,, BANGALORE

In the result, Revenue’s appeal for Assessment Year 2014-15 is partly allowed for statistical purposes

ITA 1899/BANG/2017[2014-15]Status: DisposedITAT Bangalore28 Sept 2018AY 2014-15

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boaz

For Appellant: Shri S. Ananthan, C.AFor Respondent: Smt. Neera Malhotra, CIT (D.R)
Section 115JSection 143(3)Section 14ASection 36(1)(vii)Section 36(1)(viia)Section 40

36(1)(viia) of the Act is incorrect and therefore delete the disallowance made there under. Consequently, ground NO.3 of the assessee's appeal is allowed. 8. Ground No.4 (4.1 to 4.5) – Depreciation on Investments. 8.1 In these grounds (supra), Revenue assails the order of the learned CIT (Appeals) in directing the Assessing Officer to allow the assessee's claim

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

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

ITA 318/BANG/2014[2009-10]Status: DisposedITAT Bangalore22 Jul 2016AY 2009-10

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:

For Appellant: Shri S.Ananthan, CA and Smt.Lalitha Ramaswamy, CAFor Respondent: Shri P.Chandrashekar, CIT(DR)
Section 115JSection 143(3)Section 14ASection 36(1)(vii)Section 36(1)(viia)

viia) are independent of each other. Obviously, the CIT(A) accepted ITA Nos.318 & 331/Bang/2014 Page 11 of 25 this view but however considering the evidence filed by the AO before him, held that bad debts were not actually written off as there was no corresponding debit in P&L Account. The CIT(A) placing reliance on the decision

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

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

ITA 331/BANG/2014[2009-10]Status: DisposedITAT Bangalore22 Jul 2016AY 2009-10

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:

For Appellant: Shri S.Ananthan, CA and Smt.Lalitha Ramaswamy, CAFor Respondent: Shri P.Chandrashekar, CIT(DR)
Section 115JSection 143(3)Section 14ASection 36(1)(vii)Section 36(1)(viia)

viia) are independent of each other. Obviously, the CIT(A) accepted ITA Nos.318 & 331/Bang/2014 Page 11 of 25 this view but however considering the evidence filed by the AO before him, held that bad debts were not actually written off as there was no corresponding debit in P&L Account. The CIT(A) placing reliance on the decision

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

In the result, appeal by the revenue is partly allowed

ITA 479/BANG/2009[2006-07]Status: DisposedITAT Bangalore30 Mar 2016AY 2006-07

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri G.Sarangan, Senior AdvocateFor Respondent: Shri G.R.Reddy, CIT(DR)
Section 115JSection 143(2)Section 143(3)Section 14ASection 35DSection 36(1)(viia)

viia) is not pari materia. We had gone through the provisions of sec.36(1)(viii) which are as under: “36(1) The deductions provided for in the following classes shall be allowed in respect of the matters dealt with therein, in computing the income referred to in section 28 – (viii) in respect of any special reserve created "and maintained financial

CANARA BANK,BANGALORE vs. JCIT, BANGALORE

In the result, appeal by the revenue is partly allowed

ITA 530/BANG/2010[2005-06]Status: DisposedITAT Bangalore30 Mar 2016AY 2005-06

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri G.Sarangan, Senior AdvocateFor Respondent: Shri G.R.Reddy, CIT(DR)
Section 115JSection 143(2)Section 143(3)Section 14ASection 35DSection 36(1)(viia)

viia) is not pari materia. We had gone through the provisions of sec.36(1)(viii) which are as under: “36(1) The deductions provided for in the following classes shall be allowed in respect of the matters dealt with therein, in computing the income referred to in section 28 – (viii) in respect of any special reserve created "and maintained financial

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

In the result, appeal by the revenue is partly allowed

ITA 813/BANG/2011[2007-08]Status: DisposedITAT Bangalore30 Mar 2016AY 2007-08

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri G.Sarangan, Senior AdvocateFor Respondent: Shri G.R.Reddy, CIT(DR)
Section 115JSection 143(2)Section 143(3)Section 14ASection 35DSection 36(1)(viia)

viia) is not pari materia. We had gone through the provisions of sec.36(1)(viii) which are as under: “36(1) The deductions provided for in the following classes shall be allowed in respect of the matters dealt with therein, in computing the income referred to in section 28 – (viii) in respect of any special reserve created "and maintained financial

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

In the result, appeal by the revenue is partly allowed

ITA 601/BANG/2010[2005-06]Status: DisposedITAT Bangalore30 Mar 2016AY 2005-06

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri G.Sarangan, Senior AdvocateFor Respondent: Shri G.R.Reddy, CIT(DR)
Section 115JSection 143(2)Section 143(3)Section 14ASection 35DSection 36(1)(viia)

viia) is not pari materia. We had gone through the provisions of sec.36(1)(viii) which are as under: “36(1) The deductions provided for in the following classes shall be allowed in respect of the matters dealt with therein, in computing the income referred to in section 28 – (viii) in respect of any special reserve created "and maintained financial

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

In the result, appeal by the revenue is partly allowed

ITA 530/BANG/2009[2006-07]Status: DisposedITAT Bangalore30 Mar 2016AY 2006-07

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri G.Sarangan, Senior AdvocateFor Respondent: Shri G.R.Reddy, CIT(DR)
Section 115JSection 143(2)Section 143(3)Section 14ASection 35DSection 36(1)(viia)

viia) is not pari materia. We had gone through the provisions of sec.36(1)(viii) which are as under: “36(1) The deductions provided for in the following classes shall be allowed in respect of the matters dealt with therein, in computing the income referred to in section 28 – (viii) in respect of any special reserve created "and maintained financial

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

In the result, appeal by the revenue is partly allowed

ITA 693/BANG/2012[2008-09]Status: DisposedITAT Bangalore30 Mar 2016AY 2008-09

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri G.Sarangan, Senior AdvocateFor Respondent: Shri G.R.Reddy, CIT(DR)
Section 115JSection 143(2)Section 143(3)Section 14ASection 35DSection 36(1)(viia)

viia) is not pari materia. We had gone through the provisions of sec.36(1)(viii) which are as under: “36(1) The deductions provided for in the following classes shall be allowed in respect of the matters dealt with therein, in computing the income referred to in section 28 – (viii) in respect of any special reserve created "and maintained financial

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

In the result, appeal by the revenue is partly allowed

ITA 793/BANG/2011[2007-08]Status: DisposedITAT Bangalore30 Mar 2016AY 2007-08

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri G.Sarangan, Senior AdvocateFor Respondent: Shri G.R.Reddy, CIT(DR)
Section 115JSection 143(2)Section 143(3)Section 14ASection 35DSection 36(1)(viia)

viia) is not pari materia. We had gone through the provisions of sec.36(1)(viii) which are as under: “36(1) The deductions provided for in the following classes shall be allowed in respect of the matters dealt with therein, in computing the income referred to in section 28 – (viii) in respect of any special reserve created "and maintained financial

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

In the result, appeal by the revenue is partly allowed

ITA 684/BANG/2012[2008-09]Status: DisposedITAT Bangalore30 Mar 2016AY 2008-09

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Appellant: Shri G.Sarangan, Senior AdvocateFor Respondent: Shri G.R.Reddy, CIT(DR)
Section 115JSection 143(2)Section 143(3)Section 14ASection 35DSection 36(1)(viia)

viia) is not pari materia. We had gone through the provisions of sec.36(1)(viii) which are as under: “36(1) The deductions provided for in the following classes shall be allowed in respect of the matters dealt with therein, in computing the income referred to in section 28 – (viii) in respect of any special reserve created "and maintained financial

ACIT, HUBLI vs. KARNATAKA VIKAS GRAMEEN BANK, DHARWAD

In the result, the appeal by the assessee is treated as partly allowed for statistical purpose

ITA 673/BANG/2014[2009-10]Status: DisposedITAT Bangalore25 Apr 2018AY 2009-10

Bench: Shri N.V Vasudevan & Shri Jason P Boaz

For Appellant: Shri A Shankar, AdvocateFor Respondent: Shri C.H Sundar Rao, CIT
Section 143(3)Section 36(1)(viia)

transfer to such reserve account the sum which is claimed as deduction u/s.36(1)(viii) of the Act. “Eligible business” has been defined in Explanation (b) to sec. 36(1)(viii) of the Act which is providing long term finance for development of infrastructure facility. Explanation (g) to sec. 36(1)(viii) defines what is “infrastructure facility” for the purpose