UNITED INDIA INSURANCE CO LIMITED,CHENNAI vs. PCIT-3, CHENNAI

In the result, the appeals for AY 2014-15, 2016-17 & 2017-18 are partly allowed and appeals for AY 2015-16 & 2017-18 (in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1759/Chny/2019, 182 & 183/Chny/2021, 430/Chny/2022 & 683/Chny/2023 िनधा"रण वष"/Assessment Years: 2014-15, 2015-16, 2016-17 & 2017-18 United India Insurance Co. Ltd., Vs. The Principal Commissioner Of O/O The Chief Manager, Cfac Income Tax – 3, Department, Head Office, United India Chennai 600 034. Nalanda, Door No. 19, Ground Floor, 4Th Lane, Utamar Gandhi Salai, Chennai 600 034. [Pan:Aaacu5552C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri S. Sundararaman, Ca ""थ" की ओर से/Respondent By : Ms. V. Pushpa, Sr. Standing Counsel (Virtual) सुनवाई की तारीख/ Date Of Hearing : 07.10.2025 घोषणा की तारीख /Date Of Pronouncement : 05.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: The Appeal In Ita No. 1759/Chny/2019 Filed By The Assessee Is Directed Against The Order Dated 29.03.2019 Passed By The Ld. Principal Commissioner Of Income Tax-3, Chennai For The Assessment Year 2014- 15. The Appeals In Ita No. 182 & 183/Chny/2021 Are Filed By The Assessee Against Different Orders Both Dated 28.03.2021 Passed By The Ld. Pcit-3, Chennai For The Assessment 2015-16 & 2016-17. The 2

capital gains which were exempt till AY 2010-11. He submits that the assessee started to claim deduction under section 10(38) of the Act from 5 I.T.A. No.1759/Chny/19 & Ors United India Insurance AY 2005-06 and has been allowed in the assessee’s own case both pre and post amendment of Rule 5(b) of the First Schedule

UNITED INDIA INSURANCE CO.LTD,CHENNAI vs. PCIT-3,, CHENNAI

capital gains which were exempt till AY 2010-11. He submits that the assessee started to claim deduction under section 10(38) of the Act from 5 I.T.A. No.1759/Chny/19 & Ors United India Insurance AY 2005-06 and has been allowed in the assessee's own case both pre and post amendment of Rule 5(b) of the First Schedule

ACIT, TRICHY vs. THE KARUR VYSYA BANK LTD., KARUR

In the result, I.T.A. Nos

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.1340 & 1341/Mds/2013 "नधा"रण वष" / Assessment Years : 2003-04 & 2005-06

gain 92 bond. The loss of sale of securities was allowed as business loss in the assessee's own case by the Madras High Court in T.C. No.2139 of 2008. It is 11 I.T.A. Nos.1340 & 1341/Mds/13 I.T.A. Nos. 1496 & 27/Mds/13 not in dispute that the securities are classified as stock-in-trade. Therefore, the loss in transit

THE KARUR VYSYA BANK LTD.,KARUR vs. ADDL. CIT, TRICHY

In the result, I.T.A. Nos

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.1340 & 1341/Mds/2013 "नधा"रण वष" / Assessment Years : 2003-04 & 2005-06

gain 92 bond. The loss of sale of securities was allowed as business loss in the assessee's own case by the Madras High Court in T.C. No.2139 of 2008. It is 11 I.T.A. Nos.1340 & 1341/Mds/13 I.T.A. Nos. 1496 & 27/Mds/13 not in dispute that the securities are classified as stock-in-trade. Therefore, the loss in transit

THE KARUR VYSYA BANK LTD.,KARUR vs. ADDL. CIT, TRICHY

In the result, I.T.A. Nos

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.1340 & 1341/Mds/2013 "नधा"रण वष" / Assessment Years : 2003-04 & 2005-06

gain 92 bond. The loss of sale of securities was allowed as business loss in the assessee's own case by the Madras High Court in T.C. No.2139 of 2008. It is 11 I.T.A. Nos.1340 & 1341/Mds/13 I.T.A. Nos. 1496 & 27/Mds/13 not in dispute that the securities are classified as stock-in-trade. Therefore, the loss in transit

ACIT, TRICHY vs. THE KARUR VYSYA BANK LTD., KARUR

In the result, I.T.A. Nos

Bench: Shri N.R.S. Ganesan & Shri Abraham P. Georgeआयकर अपील सं./Ita Nos.1340 & 1341/Mds/2013 "नधा"रण वष" / Assessment Years : 2003-04 & 2005-06

gain 92 bond. The loss of sale of securities was allowed as business loss in the assessee's own case by the Madras High Court in T.C. No.2139 of 2008. It is 11 I.T.A. Nos.1340 & 1341/Mds/13 I.T.A. Nos. 1496 & 27/Mds/13 not in dispute that the securities are classified as stock-in-trade. Therefore, the loss in transit

THE KARUR VYSYA BANK LTD.,KARUR vs. JCIT, TRICHY

Accordingly, the claim of the assessee that it had to be allowed on actual payment basis was, in our opinion, rightly allowed by the CIT(Appeals)

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

gains of business or profession”. The expenditure incurred in relation to stock-in-trade arising as a result of investment in shares and debentures is deductible under sections 28 to 37.” 9. Once holding of investment was considered incidental to the business of banking to the assessee, in our opinion, Section 14A of the Act could not have been applied

DCIT, TRICHY vs. THE KARUR VYSYA BANK LTD., KARUR

Accordingly, the claim of the assessee that it had to be allowed on actual payment basis was, in our opinion, rightly allowed by the CIT(Appeals)

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

gains of business or profession”. The expenditure incurred in relation to stock-in-trade arising as a result of investment in shares and debentures is deductible under sections 28 to 37.” 9. Once holding of investment was considered incidental to the business of banking to the assessee, in our opinion, Section 14A of the Act could not have been applied

THE KARUR VYSYA BANK LTD.,KARUR vs. JCIT, TRICHY

Accordingly, the claim of the assessee that it had to be allowed on actual payment basis was, in our opinion, rightly allowed by the CIT(Appeals)

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

gains of business or profession”. The expenditure incurred in relation to stock-in-trade arising as a result of investment in shares and debentures is deductible under sections 28 to 37.” 9. Once holding of investment was considered incidental to the business of banking to the assessee, in our opinion, Section 14A of the Act could not have been applied

DCIT, TRICHY vs. M/S. THE KARUR VYSYA BANK. LTD., KARUR

Accordingly, the claim of the assessee that it had to be allowed on actual payment basis was, in our opinion, rightly allowed by the CIT(Appeals)

Bench: Shri N.R.S. Ganesan & Shri Abraham P. George

gains of business or profession”. The expenditure incurred in relation to stock-in-trade arising as a result of investment in shares and debentures is deductible under sections 28 to 37.” 9. Once holding of investment was considered incidental to the business of banking to the assessee, in our opinion, Section 14A of the Act could not have been applied

CITY UNION BANK LIMITED,KUMBAKONAM vs. JCIT, KUMBAKONAM

In the result, the appeals filed for the assessment year 2007-08 filed by

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

capital expenditure as revenue expenditure without considering the facts. The Ld. AR submitted that all the government securities are treated as stock in trade and relied on the order of the CIT(A) and Jurisdictional High Court and Tribunal orders. We heard the rival submissions, perused the material on record, judicial decisions. The Ld. DR has argued that

ACIT, KUMBAKONAM vs. CITY UNION BANK LIMITED, KUMBAKONAM

In the result, the appeals filed for the assessment year 2007-08 filed by

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

capital expenditure as revenue expenditure without considering the facts. The Ld. AR submitted that all the government securities are treated as stock in trade and relied on the order of the CIT(A) and Jurisdictional High Court and Tribunal orders. We heard the rival submissions, perused the material on record, judicial decisions. The Ld. DR has argued that

CITY UNION BANK LIMITED,KUMBAKONAM vs. JCIT, KUMBAKONAM

In the result, the appeals filed for the assessment year 2007-08 filed by

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

capital expenditure as revenue expenditure without considering the facts. The Ld. AR submitted that all the government securities are treated as stock in trade and relied on the order of the CIT(A) and Jurisdictional High Court and Tribunal orders. We heard the rival submissions, perused the material on record, judicial decisions. The Ld. DR has argued that

ACIT, KUMBAKONAM vs. CITY UNION BANK LIMITED, KUMBAKONAM

In the result, the appeals filed for the assessment year 2007-08 filed by

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

capital expenditure as revenue expenditure without considering the facts. The Ld. AR submitted that all the government securities are treated as stock in trade and relied on the order of the CIT(A) and Jurisdictional High Court and Tribunal orders. We heard the rival submissions, perused the material on record, judicial decisions. The Ld. DR has argued that

ACIT, KUMBAKONAM vs. CITY UNION BANK LIMITED, KUMBAKONAM

In the result, the appeals filed for the assessment year 2007-08 filed by

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

capital expenditure as revenue expenditure without considering the facts. The Ld. AR submitted that all the government securities are treated as stock in trade and relied on the order of the CIT(A) and Jurisdictional High Court and Tribunal orders. We heard the rival submissions, perused the material on record, judicial decisions. The Ld. DR has argued that

ACIT, KUMBAKONAM vs. CITY UNION BANK LIMITED, KUMBAKONAM

In the result, the appeals filed for the assessment year 2007-08 filed by

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

capital expenditure as revenue expenditure without considering the facts. The Ld. AR submitted that all the government securities are treated as stock in trade and relied on the order of the CIT(A) and Jurisdictional High Court and Tribunal orders. We heard the rival submissions, perused the material on record, judicial decisions. The Ld. DR has argued that

ACIT, KUMBAKONAM vs. CITY UNION BANK LIMITED, KUMBAKONAM

In the result, the appeals filed for the assessment year 2007-08 filed by

Bench: Shri Chandra Poojari & Shri G. Pavan Kumar

capital expenditure as revenue expenditure without considering the facts. The Ld. AR submitted that all the government securities are treated as stock in trade and relied on the order of the CIT(A) and Jurisdictional High Court and Tribunal orders. We heard the rival submissions, perused the material on record, judicial decisions. The Ld. DR has argued that

S.ARJUN,CHENNAI vs. ACIT NON CORPORATE WARD 20(1), CHENNAI

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

Bench: Shri Abraham P. George & Shri Duvvuru Rl Reddy]

gains of business or profession, how computed.—The income referred to in section 28 shall be computed in accordance with the provisions contained in sections 30 to 43D." "37. General.—(1) Any expenditure (not being expenditure of the nature described in sections 30 to 36 and not being in the nature of capital