THE LIC EMPLOYEES CO-OPERATIVE BANK LTD.,CHENNAI vs. ACIT, CHENNAI

In the result, appeals filed by the assessee are stands allowed

Bench: Shri George Mathan & Shri S. Jayaraman

Section 194A after amendment does not indicate any retrospectively, the note explaining the clauses goes one step further in making it clear that it was intended to have prospective effect from 1.6.2015. 65. Therefore our answer to the first substantial question of law would be in favour of the assessee. Respectfully following the decision of the Hon’ble Jurisdictional High

THE LIC EMPLOYEES CO-OPERATIVE BANK LTD.,CHENNAI vs. ACIT, CHENNAI

In the result, appeals filed by the assessee are stands allowed

Bench: Shri George Mathan & Shri S. Jayaraman

Section 194A after amendment does not indicate any retrospectively, the note explaining the clauses goes one step further in making it clear that it was intended to have prospective effect from 1.6.2015. 65. Therefore our answer to the first substantial question of law would be in favour of the assessee. Respectfully following the decision of the Hon’ble Jurisdictional High

THE LIC EMPLOYEES CO-OPERATIVE BANK LTD.,CHENNAI vs. ACIT, CHENNAI

In the result, appeals filed by the assessee are stands allowed

Bench: Shri George Mathan & Shri S. Jayaraman

Section 194A after amendment does not indicate any retrospectively, the note explaining the clauses goes one step further in making it clear that it was intended to have prospective effect from 1.6.2015. 65. Therefore our answer to the first substantial question of law would be in favour of the assessee. Respectfully following the decision of the Hon’ble Jurisdictional High

THE LIC EMPLOYEES CO-OPERATIVE BANK LTD.,CHENNAI vs. ACIT, CHENNAI

In the result, appeals filed by the assessee are stands allowed

Bench: Shri George Mathan & Shri S. Jayaraman

Section 194A after amendment does not indicate any retrospectively, the note explaining the clauses goes one step further in making it clear that it was intended to have prospective effect from 1.6.2015. 65. Therefore our answer to the first substantial question of law would be in favour of the assessee. Respectfully following the decision of the Hon’ble Jurisdictional High

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

disallowance made under section 14A to the extent of dividend income earned by the assessee. In the result, the assessee’s appeal is partly allowed in this regard. 31. On the issue of the transfer pricing adjustment in respect of the investment in OFCD , the ld DR submitted that during the year, SVL had invested in the OFCDs issued

DCIT, CHENNAI vs. SIVA VENTURES LTD., CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

disallowance made under section 14A to the extent of dividend income earned by the assessee. In the result, the assessee’s appeal is partly allowed in this regard. 31. On the issue of the transfer pricing adjustment in respect of the investment in OFCD , the ld DR submitted that during the year, SVL had invested in the OFCDs issued

DCIT, CHENNAI vs. SIVA VENTURES LIMITED, CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

disallowance made under section 14A to the extent of dividend income earned by the assessee. In the result, the assessee’s appeal is partly allowed in this regard. 31. On the issue of the transfer pricing adjustment in respect of the investment in OFCD , the ld DR submitted that during the year, SVL had invested in the OFCDs issued

SIVA INDUSTRIES AND HOLDINGS LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the assessee’s appeals in ITA No 1392/2016 for the

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaraman

disallowance made under section 14A to the extent of dividend income earned by the assessee. In the result, the assessee’s appeal is partly allowed in this regard. 31. On the issue of the transfer pricing adjustment in respect of the investment in OFCD , the ld DR submitted that during the year, SVL had invested in the OFCDs issued

INDIAN OVERSEAS BANK,CHENNAI vs. DCIT,LTU(2), CHENNAI

Accordingly, this ground of Revenue is dismissed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal & Hon’Ble Shri Manu Kumar Giriआयकरअपील सं./ Ita Nos.661/Chny/2019, 202 & 203/Chny/2023 (िनधा"रणवष" / Assessment Years: 2015-16, 2016-17 & 2017-2018) Indian Overseas Bank, Vs. The Assistant Commissioner Of 763, Anna Salai, Income Tax, Chennai 600 002. Ltu (2) Chennai. आयकरअपील सं./ Ita Nos.914/Chny/2019, 253 & 254/Chny/2023 (िनधा"रणवष" / Assessment Years: 2015-16, 2016-17&2017-2018) The Assistant Commissioner Of Vs. Indian Overseas Bank, Income Tax, 763, Anna Salai, Ltu (2) Chennai 600 002. Chennai. [Pan: Aaaci 1223J] (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee By : Shri. C. Naresh, C.A., Department By : Shri. A. Sasikumar, Irs. Cit. सुनवाई क" तार"ख/Date Of Hearing : 14.11.2024 घोषणा क" तार"ख /Date Of Pronouncement : 31.12.2024

disallowed u/s. 43B for the reason that leave provision is a contractual liability and therefore, it cannot be treated at par with tax, duty, cess or fee u/s. 43B. However, in the SLP (Civil) Nos. 22889/2008 dated 08.05.2009 in the case of CIT &ors. Vs M/s. Exide Industries Ltd & ANR, wherein, the Apex Court held that “ pending hearing and final

ACIT, NON-CORPORATE CIRLE-8, CHENNAI vs. INDIAN OVERSEAS BANK, CHENNAI

disallowed u/s. 43B for the reason that leave\nprovision is a contractual liability and therefore, it cannot be\ntreated at par with tax, duty, cess or fee u/s. 43B. However,\nin the SLP (Civil) Nos. 22889/2008 dated 08.05.2009 in the\ncase of CIT &ors. Vs M/s. Exide Industries Ltd & ANR,\nwherein, the Apex Court held that “ pending hearing and final

INDIAN OVERSEAS BANK,CHENNAI vs. ACIT LTU-2, CHENNAI

disallowed u/s. 43B for the reason that leave\nprovision is a contractual liability and therefore, it cannot be\ntreated at par with tax, duty, cess or fee u/s. 43B. However,\nin the SLP (Civil) Nos. 22889/2008 dated 08.05.2009 in the\ncase of CIT &ors. Vs M/s. Exide Industries Ltd & ANR,\nwherein, the Apex Court held that “ pending hearing and final

ACIT, NON-CORPORATE CIRLE-8, CHENNAI vs. INDIAN OVERSEAS BANK, CHENNAI

disallowed u/s. 43B for the reason that leave\nprovision is a contractual liability and therefore, it cannot be\ntreated at par with tax, duty, cess or fee u/s. 43B. However,\nin the SLP (Civil) Nos. 22889/2008 dated 08.05.2009 in the\ncase of CIT &ors. Vs M/s. Exide Industries Ltd & ANR,\nwherein, the Apex Court held that “ pending hearing and final

ACIT LTU-2, CHENNAI vs. INDIAN OVERSEAS BANK, CHENNAI

disallowed u/s. 43B for the reason that leave\nprovision is a contractual liability and therefore, it cannot be\ntreated at par with tax, duty, cess or fee u/s. 43B. However,\nin the SLP (Civil) Nos. 22889/2008 dated 08.05.2009 in the\ncase of CIT &ors. Vs M/s. Exide Industries Ltd & ANR,\nwherein, the Apex Court held that “ pending hearing and final

COONOOR COOPERATIVE URBANK BANK LIMITED,COONOOR vs. DCIT,, OOTY

In the result, the appeal of the assesseein ITA No

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.228/Chny/2023 (िनधा"रणवष" / Assessment Year: 2014-2015) Coonoor Co-Operative Urban Bank Vs. The Deputy Commissioner Of Limited, Income Tax, No.15, Mount Road, Circle I, Coonoor. Ooty. [Pan: Aaaac 0793M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Miss N.V. Lakshmi, Advocate ""यथ" क" ओर से /Respondent By : Shri. Arv Srinivasan, Irs, Addl. Cit. सुनवाई क" तार"ख/Date Of Hearing : 20.06.2024 घोषणा क" तार"ख /Date Of Pronouncement : 27.08.2024 आदेश / O R D E R Per Manu Kumar Giri ()

Section 194A, 194A(3)(v), 194A(3)(vila)(b) and 194A(3) (i) (b) and disallowed the same on the ground

JCIT(OSD) CORPORATE CIRCLE-1(1), CHENNAI vs. INDIAN BANK, CHENNAI

disallow Rs.975,23,37,141/-. The\nLd. Counsel for the assesse informed that the Ld. First Appellate\nAuthority considered the issue of interpretation of Rule-6ABA for the\npurposes of section 36(1)(viia) and granted relief to the assesse.\nWhile doing so, he relied, inter-alia, upon the decision of Coordinate\nBench of this Tribunal in the case

JCIT(OSD) CORPORATE CIRCLE-1(1), CHENNAI vs. INDIAN BANK, CHENNAI

disallow Rs.975,23,37,141/-. The\nLd. Counsel for the assesse informed that the Ld. First Appellate\nAuthority considered the issue of interpretation of Rule-6ABA for the\npurposes of section 36(1)(viia) and granted relief to the assesse.\nWhile doing so, he relied, inter-alia, upon the decision of Coordinate\nBench of this Tribunal in the case

INDIAN OVERSEAS BANK,CHENNAI vs. DCIT,LTU(2), CHENNAI

disallowed u/s. 43B for the reason that leave\nprovision is a contractual liability and therefore, it cannot be\ntreated at par with tax, duty, cess or fee u/s. 43B. However,\nin the SLP (Civil) Nos. 22889/2008 dated 08.05.2009 in the\ncase of CIT &ors. Vs M/s. Exide Industries Ltd & ANR,\nwherein, the Apex Court held that “ pending hearing and final

JCIT(OSD) CORPORATE CIRCLE-1(1), CHENNAI vs. INDIAN BANK, CHENNAI

disallow Rs.975,23,37,141/-. The\nLd. Counsel for the assesse informed that the Ld. First Appellate\nAuthority considered the issue of interpretation of Rule-6ABA for the\npurposes of section 36(1)(viia) and granted relief to the assesse.\nWhile doing so, he relied, inter-alia, upon the decision of Coordinate\nBench of this Tribunal in the case