M/S GREEN STAR CORPORATION,KOLKATA vs. ACIT, CIRCLE - 45, KOLKATA, KOLKATA

In the result, the appeal of assessee is allowed in part

Bench: Hon’Ble Shri J. Sudhakar Reddy, Am & Hon’Ble Shri A. T. Varkey, Jm Assessment Year: 2011-12

250 of the Income-tax Act, 1961 ( hereinafter, referred to as the ‘Áct’) 2. The assessee is a partnership firm and is in the business of manufacturing of electrical goods. It filed its return of income for the A.Y 2011-12 relating to F.Y 2010-11 on 29-09-2011 declaring income of Rs. 29,99,051/-. The Learned Assessing

RAIGANJ CENTRAL CO-OPERATIVE BANK LTD.,RAIGANJ, UTTAR DINAJPUR vs. D.C.I.T., CIRCLE - 2, JALPAIGURI, JALPAIGURI

1,18,472/- for non-deduction of TDS under section 194-I of\nthe Act though TDS was actually made and paid to the credit of Central\nGovernment.\n26.1 It was stated that the TDS was actually made and paid to the\ncredit of the Central Government. The assessee submitted that the fact\nof this case is elaborately discussed

JASHOJIT MUKHERJEE,KOLKATA vs. ACIT, CIR-50, KOLKATA, KOLKATA

In the result, the appeal of the assessee is allowed

Bench: Hon’Ble Shri S.S. Godara, Jm & Shri M.Balaganesh, Am ] I.T.A No. 403/Kol/2017 Assessment Year : 2012-13 Jashojit Mukherjee -Vs- Acit, Circle-50, Kolkata [Pan: Afapm 7208 R] (Appellant) (Respondent)

section 41(1) of the Act are attracted. But in the instant case, the assessee before us had not written back the sundry creditors in the sum of Rs 1,08,65,202/- to its profit and loss account and had continued to show the same in its balance sheet. Hence the decision relied upon

KONINKLIJKE PHILIPS N.V.,NETHERLANDS vs. DCIT (IT), CIRCLE - 1(2), KOLKATA , KOLKATA

In the result, all the appeals of the assessee are partly allowed for statistical purpose

Bench: Shri Sonjoy Sarma & Shri Girish Agrawalita Nos.437 To 441/Kol/2021 Assessment Years: 2008-09 To 2012-13 M/S. Koninklijke Philips N.V Deputy Commissioner Of C/O Deloitte Touché Income Tax (It), Circle-1(2), Tohmatsu India Pvt. Ltd., Kolkata. Bengal Intelligent Park, Vs. Building Alpha, Block Ep & Gp, 1St Floor, Sector V, Salt Lake Electronics Complex, Kolkata-700 091. (Pan: Aacck0806B) (Appellant) (Respondent) Present For: Appellant By : Shri Ketan Ved, Ca Respondent By : Shri G. H. Sema, Addl. Cit Date Of Hearing : 22.06.2022 Date Of Pronouncement : 02.09.2022 O R D E R Per Girish Agrawal: All These Appeals By Assessee Are Directed Against The Separate Orders Of Ld. Cit(A), Kolkata-22 Vide Order Nos. Itba/Apl/S/250/2021-22/1035034204(1) Dated 23.08.2021 For A.Y. 2008-09, Itba/Apl/S/250/2021-22/1035162630(1) Dated 28.08.2021 For Ay 2009-10, Itba/Apl/S/250/2021-22/1035162589(1) Dated 28.08.2021 For Ay 2010-11, Itba/Apl/S/250/2021-22/1035162672(1) Dated 28.08.2021 For Ay 2011-12 & Itba/Apl/S/250/2021- 22/1035162702(1) Dated 28.08.2021 For Ay 2012-13 Passed Against The Assessment Order U/S 254 Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) By Acit(It), C-1(2), Kolkata Dated 23.07.2019, 13.11.2019 (For Ays 2008-09 & 2009-10) & 07.02.2020 (For Ays 2010-11 To 2012-13). Koninklijke Philips N.V, A.Ys: 2008-09 To 2012-13 2. Shri Ketan Ved, Ca Appeared On Behalf Of The Assessee & Shri G. H. Sema, Addl. Cit Appeared On Behalf Of The Revenue.

250 or section 254 or section 260 or section 262 or section 263 or section 264 shall be made within the time specified in sub-section (3).” 9. From the perusal of section 244A(1A) of the Act, we note that additional interest under this section is attracted only if the conditions of section

KONINKLIJKE PHILIPS N.V.,NETHERLANDS vs. DCIT (IT), CIRCLE - 1(2), KOLKATA , KOLKATA

In the result, all the appeals of the assessee are partly allowed for statistical purpose

Bench: Shri Sonjoy Sarma & Shri Girish Agrawalita Nos.437 To 441/Kol/2021 Assessment Years: 2008-09 To 2012-13 M/S. Koninklijke Philips N.V Deputy Commissioner Of C/O Deloitte Touché Income Tax (It), Circle-1(2), Tohmatsu India Pvt. Ltd., Kolkata. Bengal Intelligent Park, Vs. Building Alpha, Block Ep & Gp, 1St Floor, Sector V, Salt Lake Electronics Complex, Kolkata-700 091. (Pan: Aacck0806B) (Appellant) (Respondent) Present For: Appellant By : Shri Ketan Ved, Ca Respondent By : Shri G. H. Sema, Addl. Cit Date Of Hearing : 22.06.2022 Date Of Pronouncement : 02.09.2022 O R D E R Per Girish Agrawal: All These Appeals By Assessee Are Directed Against The Separate Orders Of Ld. Cit(A), Kolkata-22 Vide Order Nos. Itba/Apl/S/250/2021-22/1035034204(1) Dated 23.08.2021 For A.Y. 2008-09, Itba/Apl/S/250/2021-22/1035162630(1) Dated 28.08.2021 For Ay 2009-10, Itba/Apl/S/250/2021-22/1035162589(1) Dated 28.08.2021 For Ay 2010-11, Itba/Apl/S/250/2021-22/1035162672(1) Dated 28.08.2021 For Ay 2011-12 & Itba/Apl/S/250/2021- 22/1035162702(1) Dated 28.08.2021 For Ay 2012-13 Passed Against The Assessment Order U/S 254 Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) By Acit(It), C-1(2), Kolkata Dated 23.07.2019, 13.11.2019 (For Ays 2008-09 & 2009-10) & 07.02.2020 (For Ays 2010-11 To 2012-13). Koninklijke Philips N.V, A.Ys: 2008-09 To 2012-13 2. Shri Ketan Ved, Ca Appeared On Behalf Of The Assessee & Shri G. H. Sema, Addl. Cit Appeared On Behalf Of The Revenue.

250 or section 254 or section 260 or section 262 or section 263 or section 264 shall be made within the time specified in sub-section (3).” 9. From the perusal of section 244A(1A) of the Act, we note that additional interest under this section is attracted only if the conditions of section

KONINKLIJKE PHILIPS N.V.,NETHERLANDS vs. DCIT (IT), CIRCLE - 1(2), KOLKATA , KOLKATA

In the result, all the appeals of the assessee are partly allowed for statistical purpose

Bench: Shri Sonjoy Sarma & Shri Girish Agrawalita Nos.437 To 441/Kol/2021 Assessment Years: 2008-09 To 2012-13 M/S. Koninklijke Philips N.V Deputy Commissioner Of C/O Deloitte Touché Income Tax (It), Circle-1(2), Tohmatsu India Pvt. Ltd., Kolkata. Bengal Intelligent Park, Vs. Building Alpha, Block Ep & Gp, 1St Floor, Sector V, Salt Lake Electronics Complex, Kolkata-700 091. (Pan: Aacck0806B) (Appellant) (Respondent) Present For: Appellant By : Shri Ketan Ved, Ca Respondent By : Shri G. H. Sema, Addl. Cit Date Of Hearing : 22.06.2022 Date Of Pronouncement : 02.09.2022 O R D E R Per Girish Agrawal: All These Appeals By Assessee Are Directed Against The Separate Orders Of Ld. Cit(A), Kolkata-22 Vide Order Nos. Itba/Apl/S/250/2021-22/1035034204(1) Dated 23.08.2021 For A.Y. 2008-09, Itba/Apl/S/250/2021-22/1035162630(1) Dated 28.08.2021 For Ay 2009-10, Itba/Apl/S/250/2021-22/1035162589(1) Dated 28.08.2021 For Ay 2010-11, Itba/Apl/S/250/2021-22/1035162672(1) Dated 28.08.2021 For Ay 2011-12 & Itba/Apl/S/250/2021- 22/1035162702(1) Dated 28.08.2021 For Ay 2012-13 Passed Against The Assessment Order U/S 254 Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) By Acit(It), C-1(2), Kolkata Dated 23.07.2019, 13.11.2019 (For Ays 2008-09 & 2009-10) & 07.02.2020 (For Ays 2010-11 To 2012-13). Koninklijke Philips N.V, A.Ys: 2008-09 To 2012-13 2. Shri Ketan Ved, Ca Appeared On Behalf Of The Assessee & Shri G. H. Sema, Addl. Cit Appeared On Behalf Of The Revenue.

250 or section 254 or section 260 or section 262 or section 263 or section 264 shall be made within the time specified in sub-section (3).” 9. From the perusal of section 244A(1A) of the Act, we note that additional interest under this section is attracted only if the conditions of section

KONINKLIJKE PHILIPS N.V.,NETHERLANDS vs. DCIT (IT), CIRCLE - 1(2), KOLKATA , KOLKATA

In the result, all the appeals of the assessee are partly allowed for statistical purpose

Bench: Shri Sonjoy Sarma & Shri Girish Agrawalita Nos.437 To 441/Kol/2021 Assessment Years: 2008-09 To 2012-13 M/S. Koninklijke Philips N.V Deputy Commissioner Of C/O Deloitte Touché Income Tax (It), Circle-1(2), Tohmatsu India Pvt. Ltd., Kolkata. Bengal Intelligent Park, Vs. Building Alpha, Block Ep & Gp, 1St Floor, Sector V, Salt Lake Electronics Complex, Kolkata-700 091. (Pan: Aacck0806B) (Appellant) (Respondent) Present For: Appellant By : Shri Ketan Ved, Ca Respondent By : Shri G. H. Sema, Addl. Cit Date Of Hearing : 22.06.2022 Date Of Pronouncement : 02.09.2022 O R D E R Per Girish Agrawal: All These Appeals By Assessee Are Directed Against The Separate Orders Of Ld. Cit(A), Kolkata-22 Vide Order Nos. Itba/Apl/S/250/2021-22/1035034204(1) Dated 23.08.2021 For A.Y. 2008-09, Itba/Apl/S/250/2021-22/1035162630(1) Dated 28.08.2021 For Ay 2009-10, Itba/Apl/S/250/2021-22/1035162589(1) Dated 28.08.2021 For Ay 2010-11, Itba/Apl/S/250/2021-22/1035162672(1) Dated 28.08.2021 For Ay 2011-12 & Itba/Apl/S/250/2021- 22/1035162702(1) Dated 28.08.2021 For Ay 2012-13 Passed Against The Assessment Order U/S 254 Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) By Acit(It), C-1(2), Kolkata Dated 23.07.2019, 13.11.2019 (For Ays 2008-09 & 2009-10) & 07.02.2020 (For Ays 2010-11 To 2012-13). Koninklijke Philips N.V, A.Ys: 2008-09 To 2012-13 2. Shri Ketan Ved, Ca Appeared On Behalf Of The Assessee & Shri G. H. Sema, Addl. Cit Appeared On Behalf Of The Revenue.

250 or section 254 or section 260 or section 262 or section 263 or section 264 shall be made within the time specified in sub-section (3).” 9. From the perusal of section 244A(1A) of the Act, we note that additional interest under this section is attracted only if the conditions of section

KONINKLIJKE PHILIPS N.V.,NETHERLANDS vs. DCIT (IT), CIRCLE - 1(2), KOLKATA , KOLKATA

In the result, all the appeals of the assessee are partly allowed for statistical purpose

Bench: Shri Sonjoy Sarma & Shri Girish Agrawalita Nos.437 To 441/Kol/2021 Assessment Years: 2008-09 To 2012-13 M/S. Koninklijke Philips N.V Deputy Commissioner Of C/O Deloitte Touché Income Tax (It), Circle-1(2), Tohmatsu India Pvt. Ltd., Kolkata. Bengal Intelligent Park, Vs. Building Alpha, Block Ep & Gp, 1St Floor, Sector V, Salt Lake Electronics Complex, Kolkata-700 091. (Pan: Aacck0806B) (Appellant) (Respondent) Present For: Appellant By : Shri Ketan Ved, Ca Respondent By : Shri G. H. Sema, Addl. Cit Date Of Hearing : 22.06.2022 Date Of Pronouncement : 02.09.2022 O R D E R Per Girish Agrawal: All These Appeals By Assessee Are Directed Against The Separate Orders Of Ld. Cit(A), Kolkata-22 Vide Order Nos. Itba/Apl/S/250/2021-22/1035034204(1) Dated 23.08.2021 For A.Y. 2008-09, Itba/Apl/S/250/2021-22/1035162630(1) Dated 28.08.2021 For Ay 2009-10, Itba/Apl/S/250/2021-22/1035162589(1) Dated 28.08.2021 For Ay 2010-11, Itba/Apl/S/250/2021-22/1035162672(1) Dated 28.08.2021 For Ay 2011-12 & Itba/Apl/S/250/2021- 22/1035162702(1) Dated 28.08.2021 For Ay 2012-13 Passed Against The Assessment Order U/S 254 Of The Income-Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) By Acit(It), C-1(2), Kolkata Dated 23.07.2019, 13.11.2019 (For Ays 2008-09 & 2009-10) & 07.02.2020 (For Ays 2010-11 To 2012-13). Koninklijke Philips N.V, A.Ys: 2008-09 To 2012-13 2. Shri Ketan Ved, Ca Appeared On Behalf Of The Assessee & Shri G. H. Sema, Addl. Cit Appeared On Behalf Of The Revenue.

250 or section 254 or section 260 or section 262 or section 263 or section 264 shall be made within the time specified in sub-section (3).” 9. From the perusal of section 244A(1A) of the Act, we note that additional interest under this section is attracted only if the conditions of section

RAIGANJ CENTRAL CO-OPERATIVE BANK LTD.,RAIGANJ, UTTAR DINAJPUR vs. JCIT (TDS), RANGE - 6, SILIGURI

1,18,472/- for non-deduction of TDS under section 194-I of\nthe Act though TDS was actually made and paid to the credit of Central\nGovernment.\n26.1 It was stated that the TDS was actually made and paid to the\ncredit of the Central Government. The assessee submitted that the fact\nof this case is elaborately discussed

M/S. BINDHYA BASHINI TRADERS ,LILUAH, HOWRAH vs. D.C.I.T., CIRCLE - 32, KOLKATA, KOLKATA

The appeal of the assessee is hereby dismissed and the order of the Ld

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishraassessment Year: 2018-19 & Assessment Year: 2019-20 M/S Bindhya Bashini Traders, Circle – 32, Kolkata, 268/10, Narayani Complex, Aayakar Bhawan, 110, Vs G.T. Road, Liluah - 711204 Middletown Row, (Pan: Aagfb2388A) Kolkata - 700071 (Appellant) (Respondent)

250 is bad in law as well as on facts of the case. 2. That the Hon’ble CIT(A), NFAC erred in law as well as on facts of the case by confirming disallowance of Rs. 29,45,807/- of delay in deposit of PF/ESI made by CPC, which was beyond jurisdiction. 3. That the appellant craves to leave

M/S. BINDHYA BASHINI TRADERS,LIUAH, HOWRAH vs. DCIT, CIRCLE - 32, KOLKATA, KOLKATA

The appeal of the assessee is hereby dismissed and the order of the Ld

Bench: Shri Pradip Kumar Choubey & Shri Rakesh Mishraassessment Year: 2018-19 & Assessment Year: 2019-20 M/S Bindhya Bashini Traders, Circle – 32, Kolkata, 268/10, Narayani Complex, Aayakar Bhawan, 110, Vs G.T. Road, Liluah - 711204 Middletown Row, (Pan: Aagfb2388A) Kolkata - 700071 (Appellant) (Respondent)

250 is bad in law as well as on facts of the case. 2. That the Hon’ble CIT(A), NFAC erred in law as well as on facts of the case by confirming disallowance of Rs. 29,45,807/- of delay in deposit of PF/ESI made by CPC, which was beyond jurisdiction. 3. That the appellant craves to leave

RAIGANJ CENTRAL CO-OPERATIVE BANK LTD.,RAIGANJ, UTTAR DINAJPUR vs. D,C,I.T., CIRCLE - 2, JALPAIGURI, JALPAIGURI

In the result, the appeal filed by the Revenue in ITA No

Bench: Shri George Mathan & Shri Rakesh Mishra

TDS), Range-6, Bank Ltd. Vs. Siliguri (Appellant) (Respondent) PAN: AAAAR6191E Appearances: Assessee represented by : N.C. Mondal, AR. Department represented by : Monalisha Pal Mukherjee, JCIT, Sr. DR. Date of concluding the hearing : 27-November-2025 Date of pronouncing the order : 11-February-2026 ORDER PER RAKESH MISHRA, ACCOUNTANT MEMBER: These appeals filed by the assessee are against the separate orders

M/S CAPITAL TOURS(INDIA) PVT. LTD ,KOLKATA vs. ITO, WARD-12(1), KOLKATA

In the result, the appeal of the assessee is treated as partly allowed

Bench: Shri Sanjay Garg & Dr. Manish Boradi.T.A No.507/Kol/2020 Assessment Year: 2015-16 M/S Capital Tours (India) Pvt. Ltd..............................………...…..…Appellant 1, J Embassy Building, 4, Shakepeare Sarani, Kolkata- 700 071. [Pan: Aabcc2821K] Vs. Ito, Ward-12(1), Kolkata......................................................…..…..Respondent Appearances By: Shri Miraj D Shah, Ar, Appeared On Behalf Of The Appellant. Shri P. P Barman, Addl. Cit-Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : January 17, 2023 Date Of Pronouncing The Order : March 16, 2023 आदेश / Order संजय गग", "या"यक सद"य "वारा / Per Sanjay Garg: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 07.06.2019 Of The Commissioner Of Income Tax (Appeals)-17, Kolkata [Hereinafter Referred To As The ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. The Assessee In This Appeal Has Taken The Following Grounds Of Appeal: “1. That The Order Passed By The Ld. Cit (Appeals)-17, Kolkata U/S 250 Confirming The Additions & Disallowances Made By Learned Assessing Officer Is Wrong In The Law & Facts Of The Case. 2. That The Ld. Cit (Appeals) - 17, Kolkata Erred In Law As Well As On Facts Of The Case By Confirming The Disallowance Of Employee'S Contribution For

250 confirming the additions and disallowances made by learned assessing officer is wrong in the law and facts of the case. 2. That the Ld. CIT (Appeals) - 17, Kolkata erred in law as well as on facts of the case by confirming the disallowance of Employee's Contribution for I.T.A No.507/Kol/2020 Assessment year: 2015-16 M/s Capital Tours (India

MEGA ENGINEERS & BUILDERS,PORT BLAIR vs. DCIT, CIR. 3(2) , PORT BLAIR

In the result, the appeal of assessee is allowed

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

1,28,350/- and Sanskriti Sarees Rs. 76,250/-. However, the TDS on the above payments were made at the rate of 2% u/s 194C whereas as a matter of fact, TDS should have been deducted at the rate of 10% u/s 194A of the Act. Finally, the AO disallowed 30% of the above interest payment being disallowance

ANUNOY MUKHERJEE,DURGAPUR vs. I.T.O., WARD-1(4), DURGAPUR, DURGAPUR

In the result, appeal of the assessee is allowed

Bench: Shri Sanjay Garg, Hon’Ble & Dr. Manish Borad, Hon’Blei.T.A. No. 555/Kol/2022 Assessment Year: 2017-18 Anunoy Mukherjee Income Tax Officer, Ward-1 Vs (4), Durgapur Near Hdfc Bank Bamunara Kanksa Durgapur - 713212 [Pan : Cydpm3295A] अपीलाथ"/ (Appellant) "" यथ"/ (Respondent) Assessee By : Shri Vishal Kr. Agrawal, C.A. & Shri Rohitash Gupta, C.A. Revenue By : Shri P.P. Barman, Addl. Cit, Sr. D/R सुनवाई क" तार"ख/Date Of Hearing : 16/02/2023 घोषणा क" तार"ख /Date Of Pronouncement: 23/02/2023 आदेश/O R D E R Per Dr. Manish Borad: The Present Appeal Is Directed At The Instance Of The Assessee Against The Order Of The National Faceless Appeal Centre, Delhi (Hereinafter The “Ld. Cit(A)”) Dated 21/07/2022, Passed U/S 250 Of The Income Tax Act, 1961 (‘The Act’), For Assessment Year 2017-18. 2. The Registry Has Pointed Out That There Is A Delay Of One (1) Day In Filing Of This Appeal In Time Before The Tribunal. The Assessee Has Filed A Petition For Condonation Of Delay Stating The Reasons Of Delay. After Perusing The Same, We Find That The Assessee Was Prevented By Sufficient Cause From Filing The Appeal In Time Before The Tribunal. Hence, The Delay Is Condoned & The Appeal Is Admitted. 3. The Only Issue That Arises For Our Consideration Is Whether The Ld. Cit(A) Was Justified In Confirming The Penalty U/S 271B Of The Act At Rs.1,36,214/-, Levied For Not Getting The Books Of Account Audited U/S 44Ab Of The Act.

250 of the Income Tax Act, 1961 (‘the Act’), for Assessment Year 2017-18. 2. The Registry has pointed out that there is a delay of one (1) day in filing of this appeal in time before the Tribunal. The assessee has filed a petition for condonation of delay stating the reasons of delay. After perusing the same, we find

SREI INFRASTRUCTURE FINANCE LIMITED,KOLKATA vs. ACIT,CIR-11(1), KOL, KOLKATA

In the result, appeal of the assessee is allowed

Bench: Shri Rajpal Yadav & Dr. Manish Boradi.T.A. No.1157/Kol/2023 Assessment Year: 2017-18 Srei Infrastructure Finance Ltd. ………. Appellant (Pan: Aaacs1425L) Vs. Acit, Circle-11(1), Kolkata ……. Respondent Appearances By: Shri S. K. Tulsiyan, Advocate & Sm. Lata Goyal, Aca Appeared For Appellant Shri S. Datta, Cit, Dr Appeared For Respondent . Date Of Hearing : 07.02.2024 Date Of Pronouncing The Order : 29.04.2024 Order Per Manish Borad: This Appeal Filed By The Assessee Pertaining To The Assessment Year (In Short “Ay”) 2017-18 Is Directed Against The Order Passed U/S 250 Of The Income Tax Act, 1961 In Short The “Act”) By Ld. Commissioner Of Income-Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi [In Short Ld. “Cit(A)”] Dated 05.09.2023 Arising Out Of The Assessment Order U/S. 154 R,W,S, 143(3) Of The Act By Acit, Circle-11(1), Kolkata Dated 12.07.2022. 2. Grounds Of Appeal Raised By The Assessee Are Reproduced As Under: “1. That On The Facts & In The Circumstances Of The Case, The Learned Commissioner Of Income Tax (Appeal), [Here- In- After Referred To As Ld. Cit(A)] Was Not Justified & Grossly Erred In Not Granting The Interest U/S. 244A Of The Income Tax Act, 1961 ('The Act').

250 of the Income Tax Act, 1961 in short the “Act”) by Ld. Commissioner of Income-tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [in short Ld. “CIT(A)”] dated 05.09.2023 arising out of the Assessment order u/s. 154 r,w,s, 143(3) of the Act by ACIT, Circle-11(1), Kolkata dated 12.07.2022. 2. Grounds of appeal raised

DCIT, CIR-2(1), KOLKATA, KOLKATA vs. M/S ROYAL BANK OF SCOTLAND N.V., KOLKATA

Accordingly, the Ground Nos. (iv) to (vi) raised by the revenue are dismissed

Bench: Hon’Ble Shri Aby. T. Varkey, Jm & Shri M.Balaganesh, Am ] I.T.A No. 503/Kol/2016 Assessment Year : 2011-12 Dcit (It), Circle-2(1), Kolkata -Vs- M/S Royal Bank Of Scotland N.V. [Pan: Aacca 6818 K] (Appellant) (Respondent) I.T.A No. 505/Kol/2016 Assessment Year : 2011-12 M/S Royal Bank Of Scotland N.V. -Vs- Dcit (It), Circle-2(1), Kolkata [Pan: Aacca 6818 K] (Appellant) (Respondent)

TDS thereon). • During the year under consideration, the Bank has made payments to the employees amounting to Rs 4.09 crore towards such unfunded pension liability. the payment has been incurred wholly and exclusively for the purposes of the business of the Bank, the same has been claimed as deduction by the Bank under Section 37(1

THE ROYAL BANK OF SCOTLAND N.V.,KOLKATA vs. DCIT, (IT) - 2(1), KOLKATA, KOLKATA

Accordingly, the Ground Nos. (iv) to (vi) raised by the revenue are dismissed

Bench: Hon’Ble Shri Aby. T. Varkey, Jm & Shri M.Balaganesh, Am ] I.T.A No. 503/Kol/2016 Assessment Year : 2011-12 Dcit (It), Circle-2(1), Kolkata -Vs- M/S Royal Bank Of Scotland N.V. [Pan: Aacca 6818 K] (Appellant) (Respondent) I.T.A No. 505/Kol/2016 Assessment Year : 2011-12 M/S Royal Bank Of Scotland N.V. -Vs- Dcit (It), Circle-2(1), Kolkata [Pan: Aacca 6818 K] (Appellant) (Respondent)

TDS thereon). • During the year under consideration, the Bank has made payments to the employees amounting to Rs 4.09 crore towards such unfunded pension liability. the payment has been incurred wholly and exclusively for the purposes of the business of the Bank, the same has been claimed as deduction by the Bank under Section 37(1