ACIT, CIRCLE-2(1)(1), MUMBAI vs. M/S BANK OF INDIA, MUMBAI

In the result, the appeal by the Revenue for the assessment year 2018-

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailita No.1452/Mum/2023 Assessment Year : 2016-17 Assessment Year : 2018-19

section 143(3) of the Act, disagreed with the submissions of the assessee and held that perpetual bonds are in the nature of debt instruments with no maturity date. Only the issuing company can buy back the bonds from the investors. Therefore, it was held these bonds are perpetual in nature. Since in the case of perpetual bonds, the investor

DY. COMMISSIONER OF INCOME TAX CIRCLE - 3(3)(1), MUMBAI, MUMBAI vs. SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA, MUMBAI

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

2: Claim for deduction under Section 36(1)(viia)(c) after reducing from the appellant's income deduction under Section 36(1) (viii) of the Act:- 16 ITA 2943-2894-2893-3160-3173/M/ 2023 & 2971-2970/M/ 2023 Small Industries Development Bank of India 19. The issue which arises is whether deduction should be firstly allowed in terms

DY. COMMISSIONER OF INCOME TAX CIRCLE - 3(3)(1), MUMBAI , MUMBAI vs. SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA, MUMBAI

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

2: Claim for deduction under Section 36(1)(viia)(c) after reducing from the appellant's income deduction under Section 36(1) (viii) of the Act:- 16 ITA 2943-2894-2893-3160-3173/M/ 2023 & 2971-2970/M/ 2023 Small Industries Development Bank of India 19. The issue which arises is whether deduction should be firstly allowed in terms

DY. COMMISSIONER OF INCOME TAX CIRCLE - 3(3)(1), MUMBAI, MUMBAI vs. SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA, MUMBAI

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

2: Claim for deduction under Section 36(1)(viia)(c) after reducing from the appellant's income deduction under Section 36(1) (viii) of the Act:- 16 ITA 2943-2894-2893-3160-3173/M/ 2023 & 2971-2970/M/ 2023 Small Industries Development Bank of India 19. The issue which arises is whether deduction should be firstly allowed in terms

SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX CIRCLE 3(3)(1),MUMBAI, MUMBAI

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

2: Claim for deduction under Section 36(1)(viia)(c) after reducing from the appellant's income deduction under Section 36(1) (viii) of the Act:- 16 ITA 2943-2894-2893-3160-3173/M/ 2023 & 2971-2970/M/ 2023 Small Industries Development Bank of India 19. The issue which arises is whether deduction should be firstly allowed in terms

CITIZENCREDIT CO OPERATIVE BANK LIMITED ( BORIVILI BRANCH),MUMBAI vs. ITO (TDS)1(1)(4), MUMBAI

In the results, all the appeals of the assessee are dismissed

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

24,929 u/s 201(1)/201(1A) of the I. T. Act, 1961, aggregating to Rs. 54,257 deserves to be deleted in toto. 3. According to the order passed by the TDS authority, consequent to a of survey proceedings, it was noticed that the assessee, being a Cooperative bank had not deducted and deposited TDS u/s.194A on interest paid

STATE BANK OF MYSORE,BANGALORE vs. JCIT, BANGALORE

In the result, the appeal of the Revenue Ground-3 is dismissed

Bench: Shri Narendra Kumar Billaiya, Account Member & Shri Anikesh Banerjeestate Bank Of India Vs Joint Commissioner Of Income-Tax, (Erstwhile State Bank Of Large Tax Payers Unit, Bangalore Mysore Prior To Merger) Local Head Office Compliance Department, 4Th Floor, 65, St. Marks Road, Bangalore-560 001 Pan: Aaccs0155P Appellant Respondent Deputy Commissioner Of Vs State Bank Of Mysore Income-Tax, Ltu, Circle-1, Head Office, Finance & Accounts Bangalore Department, Kg Road, Bangalore- 560 009 Pan: Aaccs0155P Appellant Respondent

2(i) of assessee related deduction in relation to rural branch is duly rejected. Ground 3: Disallowance of excess depreciation on Automated Teller Machies [‘ATM’] and other computer peripherals by reclassifying as plant and machinery – Rs.9,74,43,086/- 12. On this issue, the assessee claimed depreciation under section 32 of the Act at 60% by treating the ATMs

ACIT, CIRCLE -3(4), MUMBAI, MUMBAI vs. UNION BANK OF INDIA, MUMBAI

In the result, the appeal of the revenue is dismissed

viia) of the Act and it can only claim deduction under section\n36(1)(vii) of the Act, if there is any recovery, it can be charged to tax under\nsection 41(4) of the Act. Therefore, the proposed addition of recovery of bad\ndebts by the Assessing Officer is not proper and observation of Ld.CIT(A) is\nalso

M/S UNION BANK OF INDIA,MUMBAI vs. DCIT, CIRCLE-(LTU) 2, MUMBAI

In the result, the appeal of the revenue is dismissed

viia) of the Act and it can only claim deduction under section\n36(1)(vii) of the Act, if there is any recovery, it can be charged to tax under\nsection 41(4) of the Act. Therefore, the proposed addition of recovery of bad\ndebts by the Assessing Officer is not proper and observation of Ld.CIT(A) is\nalso

M/S THE MAHARASHTRA STATE CO. OP BANK LTD.,MUMBAI vs. ITO-1(3)(3), MUMBAI

In the result, the appeal of the In the result, the appeal of the assessee is allowed partly assessee is allowed partly whereas the appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2013-14

24,50,45,356/- should have been offered for taxation should have been offered for taxation and against which the bank claims full TDS amount. against which the bank claims full TDS amount. against which the bank claims full TDS amount. However, the assessee bank has claimed full TDS amount in However, the assessee bank has claimed full TDS amount

DY CIT-1(3)(2), MUMBAI vs. MAHARASHTRA STATE CO-OPERATIVE BANK LIMITED, MUMBAI

In the result, the appeal of the In the result, the appeal of the assessee is allowed partly assessee is allowed partly whereas the appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2013-14

24,50,45,356/- should have been offered for taxation should have been offered for taxation and against which the bank claims full TDS amount. against which the bank claims full TDS amount. against which the bank claims full TDS amount. However, the assessee bank has claimed full TDS amount in However, the assessee bank has claimed full TDS amount

BLOOM PACKAGING P LTD,MUMBAI vs. ASST CIT CEN CIR 39, MUMBAI

In the result, appeal of the assessee is allowed

Bench: Shri D. Karunakara Rao & Shri Amit Shukla

viia) & 56(2)(viib) of the Act. 13. Similarly, we analyse the provisions of section 28(iv) of the Act. These provisions imply the arising of any benefit / perquisite to the assessee-firm. On facts of the present case, we find, there is no such any benefit or perquisite to the assessee firm by transfer of shares

CITIZENCREDIT CO-OPERATIVE BANK LIMITED (HILL ROAD BRANCH),MUMBAI vs. ITO (TDS)-WARD 1(1)(4), MUMBAI

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

2) [Omitted by the Finance Act, 1992, w.e.f. 1-6-1992.] 17 ==End of OCR for page 17== ITA Nos.6035 to 6042 & 6385 to 6442/M/2025 Citizen Credit Co-operative Bank Ltd. (3) The provisions of sub-section (1) shall not apply- (i) where the amount of such income or, as the case may be, the aggregate of the amounts

CITIZENCREDIT CO-OPERATIVE BANK LIMITED (MANORI BRANCH),MUMBAI vs. ITO (TDS)-WARD 1(1)(4), MUMBAI

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

section 250 of the Income-tax Act, 1961 (in short, ‘Act') by the Addl./JCIT (A) – 10, Delhi, Office of the Commissioner of Income-tax (Appeals), dated 05.09.2025 [in short, ‘CIT(A)'] for the assessment years (AYs) 2016-17, 2017-18, 2018-19 and 2019-20. Since the issues in these appeal are similar except variance in amounts, therefore, with

CITIZEN CREDIT CO-OPERATIVE BANK LTD (SAHAR BRANCH),MUMBAI vs. ITO (TDS)-1(1)(4), MUMBAI

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

section 250 of the Income-tax Act, 1961 (in short, ‘Act') by the Addl./JCIT (A) – 10, Delhi, Office of the Commissioner of Income-tax (Appeals), dated 05.09.2025 [in short, ‘CIT(A)'] for the assessment years (AYs) 2016-17, 2017-18, 2018-19 and 2019-20. Since the issues in these appeal are similar except variance in amounts, therefore, with

CITIZENCREDIT CO-OPERTIVE BANK LIMITED (COLABA BRANCH),MUMBAI vs. ITO (TDS) WARD 1(1)(4), MUMBAI

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

2) [Omitted by the Finance Act, 1992, w.e.f. 1-6-1992.] 17 ITA Nos.6035 to 6042 & 6385 to 6442/M/2025 Citizen Credit Co-operative Bank Ltd. (3) The provisions of sub-section (1) shall not apply- (i) where the amount of such income or, as the case may be, the aggregate of the amounts of such income credited or paid

CITIZENCREDIT CO-OPERATIVE BANK LIMITED (HILL ROAD BRANCH) ,MUMBAI vs. ITO (TDS)-WARD 1(1)(4), MUMBAI

Bench: Shri Narender Kumar Choudhry & Shri Bijayananda Pruseth

24 Co-op. housing societies. Therefore, it was not required to deduct Tax u/s 194A of the Act. 13.1 In view of the rival contention by the parties, we have again perused provisions of section 194A(1), 194A(3)(i)(b), 194A(3)(v) and 194A(3)(viia)(b) of the Act. Section 194A(1) requires any person, other than

HDFC BANK LIMITED (AS SUCCESSOR TO HOUSING DEVELOPMENT FINANCE CORPORATION LTD),MUMBAI vs. DCIT RG 1(1), MUMBAI

Bench: Shri Anikesh Banerjee & Shri Girish Agrawal

viia) of the Act. XXII. Deduction of bad debts u/s.36(1)(vii) of the Act. XXIII. Addition of interest income on income-tax refund. XXIV. Dropping penalty proceeding initiated u/s.270A of the Act. XXV. Penalty imposed u/s.271(1)(c) on disallowance on deduction u/s.36(1)(viii) 3. Relevant grounds for each of the assessment years, both in the case