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

194A of the IT Act treating it as Interest. The AO taxed proportionate Interest of Rs.3,33,00,000/- as Income of the appellant. 5.3.1 The appellant submitted that the Intention was to derive value of a large project and M/S Sahara India Commercial Corporation Ltd. decided not to sell land to it and compensated it. It was submitted that

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

194A of the IT Act treating it as Interest. The AO taxed proportionate Interest of Rs.3,33,00,000/- as Income of the appellant. 5.3.1 The appellant submitted that the Intention was to derive value of a large project and M/S Sahara India Commercial Corporation Ltd. decided not to sell land to it and compensated it. It was submitted that

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

194A of the IT Act treating it as Interest. The AO taxed proportionate Interest of Rs.3,33,00,000/- as Income of the appellant. 5.3.1 The appellant submitted that the Intention was to derive value of a large project and M/S Sahara India Commercial Corporation Ltd. decided not to sell land to it and compensated it. It was submitted that

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

194A of the IT Act treating it as Interest. The AO taxed proportionate Interest of Rs.3,33,00,000/- as Income of the appellant. 5.3.1 The appellant submitted that the Intention was to derive value of a large project and M/S Sahara India Commercial Corporation Ltd. decided not to sell land to it and compensated it. It was submitted that

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 ()

iv) Disallowance of Rs.48,76,149/- being contribution unrecognized staff provident fund by employee. (v) Disallowance u/s.40 (a)(ia) of Rs.4,82,97,933/- interest paid on various deposits for want of Tax Deduction at source on ground of applicability of Section 194A (1)’’. 3

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 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

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. 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

DEPUTY COMMISSIONER OF INCOME TAX, SALEM vs. GOVINDA RAJULU SRINIVASAN, SALEM

In the result, appeal of the Revenue stands dismissed

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

iv) Disallowance of JCB expenses - Rs.3,01,000 (v) Disallowance of legal expenses - Rs.22,00,000 (vi) Disallowance of advertisement exp - Rs.87,280 (vii) Disallowance of compensation exp - Rs.4,00,000 (viii) Disallowance of audit fees u/s 40(a)(ia) - Rs.60,000 (ix)Disallowance of marketing exp - Rs.4,19,052 (x)Disallowance of travelling expenses - Rs.36,99,567 (xi) Disallowance

CITY UNION BANK LIMITED,KUMBAKONAM vs. ACIT CIRCLE 1, KUMBAKONAM

In the result, appeal of the Revenue in ITA 1316/CHNY/2018

Bench: Shri George Mathan & Shri Inturi Rama Rao

iv) of the Act with regard to unclaimed money, stale drafts and cheques reflected in the balance sheet for more than three year by applying the principle of limitation and the notification of RBI was issued on 24/05/2014 only, mandating the banks to transfer such unclaimed amount to "Depositor Education and Awareness Fund Scheme" and this instruction is prospective only

ACIT CIRCLE 1, KUMBAKONAM vs. CITY UNION BANK LIMITED, KUMBAKONAM

In the result, appeal of the Revenue in ITA 1316/CHNY/2018

Bench: Shri George Mathan & Shri Inturi Rama Rao

iv) of the Act with regard to unclaimed money, stale drafts and cheques reflected in the balance sheet for more than three year by applying the principle of limitation and the notification of RBI was issued on 24/05/2014 only, mandating the banks to transfer such unclaimed amount to "Depositor Education and Awareness Fund Scheme" and this instruction is prospective only

CITY UNION BANK LIMITED,KUMBAKONAM vs. ACIT CIRCLE 1, KUMBAKONAM

In the result, appeal of the Revenue in ITA 1316/CHNY/2018

Bench: Shri George Mathan & Shri Inturi Rama Rao

iv) of the Act with regard to unclaimed money, stale drafts and cheques reflected in the balance sheet for more than three year by applying the principle of limitation and the notification of RBI was issued on 24/05/2014 only, mandating the banks to transfer such unclaimed amount to "Depositor Education and Awareness Fund Scheme" and this instruction is prospective only

ACIT CIRCLE 1, KUMBAKONAM vs. CITY UNION BANK LIMITED, KUMBAKONAM

In the result, appeal of the Revenue in ITA 1316/CHNY/2018

Bench: Shri George Mathan & Shri Inturi Rama Rao

iv) of the Act with regard to unclaimed money, stale drafts and cheques reflected in the balance sheet for more than three year by applying the principle of limitation and the notification of RBI was issued on 24/05/2014 only, mandating the banks to transfer such unclaimed amount to "Depositor Education and Awareness Fund Scheme" and this instruction is prospective only

DCIT, CHENNAI vs. SHRIRAM OWNERSHIP TRUST, CHENNAI

In the result, appeal filed by the Revenue is partly

Bench: Shri Mahavir Singh, Vice- & Shri G. Manjunatha

194A treat Private Discretionary Trusts (PDTs) as individuals for the benefits of those sections. 2 3. The Ld.CIT(A) erred in not applying the above rationale Mutatis mutandis for the purposes of taxability of income too under section 56(2) PDTs to be treated as individuals. Further, the Ld.CIT(A) erred in the application of the Act by changing variably

ACIT CIRCLE 1, KUMBAKONAM vs. CITY UNION BANK LTD., KUMBAKONAM

In the result, appeal filed by the revenue for assessment year 2017-18 is partly allowed for statistical purposes

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकर अपील सं./Ita Nos.: 1120 & 1121/Chny/2019 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17 M/S. City Union Bank Ltd., Asst. Commissioner Of Income- Administrative Office V. Tax, “Narayana” Circle -1, 24-B, Gandhi Nagar, Kumbakonam. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.: 672/Chny/2020 िनधा"रण वष" / Assessment Year: 2017-18 M/S. City Union Bank Ltd., Deputy Commissioner Of Administrative Office V. Income-Tax, “Narayana” Circle -2(1), 24-B, Gandhi Nagar, Trichy. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.: 1418 & 1419/Chny/2019 िनधा"रण वष" / Assessment Years: 2015-16, 2016-17 Asst. Commissioner Of M/S. City Union Bank Ltd., Income-Tax, V. Administrative Office “Narayana” Circle -1, 24-B, Gandhi Nagar, Kumbakonam. Kumbakonam- 612 001. [Pan: Aaacc-1287-E] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.: 636/Chny/2020 िनधा"रण वष" / Assessment Year: 2017-18 Deputy Commissioner Of M/S. City Union Bank Ltd., Income-Tax, V. Administrative Office “Narayana” Circle -2(1), 24-B, Gandhi Nagar

iv) of the Act. However, sustained additions made towards NPA provisions claimed as write off, disallowance of CSR expenses, expenses of shares allotted under ESOS, disallowance u/s. 40(a)(ia) of the Act, expenses of QIP issue of shares, bad debts provisions u/s. 36(1)(viia) of the Act, non-rural bad debts written off and profit from eligible business