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

Disallowance of deduction under section 36(1)(vii) 5. During the year under consideration, the assessee has claimed bad-debts amounting to Rs. 175,65

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

Disallowance of deduction under section 36(1)(vii) 5. During the year under consideration, the assessee has claimed bad-debts amounting to Rs. 175,65

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

Disallowance of deduction under section 36(1)(vii) 5. During the year under consideration, the assessee has claimed bad-debts amounting to Rs. 175,65

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

Disallowance of deduction under section 36(1)(vii) 5. During the year under consideration, the assessee has claimed bad-debts amounting to Rs. 175,65

STATE BANK OF INDIA,MUMBAI vs. ADDL CIT RG 2(2), MUMBAI

In the result, the appeal of the assessee is partly allowed and the appeal of the Revenue is dismissed, as indicated above

Bench: Sri Mahavir Singh, Vp & Sri G Manjunatha, Am आयकर अपील सुं./ Ita No. 3644/Mum/2016 (ननर्ाारण वर्ा / Assessment Year 2008-09) State Bank Of India The Dy. Commissioner Of 3Rd Floor, Corporate Centre Income Tax, Circle -2(2)(1) बनाम/ Madam Cama Road Mumbai Vs. Nariman Point Mumbai-400021 (अपीलार्थी / Appellant) (प्रत्यर्थी/ Respondent) स्र्थायी लेखा सुं./Pan No. Aaacs8577K

65 | P a g e State Bank of India ITA Nos.3644&4563/Mum/2016 (viia). The proviso to Section 36(1)(vii) will relate to cases covered under Section 36(1)(viia) and has to be read with Section 36(2)(v) of the Act. Thus, the proviso would not permit benefit of double deduction, operating with reference to rural loans while

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

65,10,683/- under section 36(1)(vii) r.w.s.36(2) of the Act.\nThe assessee also claimed an amount of Rs.81,73,55,929/- as provision for\ndoubtful debts under section 36(1)(viia)(c) of the Act at 5% of total income. The\nAO held that the claim of bad-debts under section 36(1)(vii) is subject

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

65,10,683/- under section 36(1)(vii) r.w.s.36(2) of the Act.\nThe assessee also claimed an amount of Rs.81,73,55,929/- as provision for\ndoubtful debts under section 36(1)(viia)(c) of the Act at 5% of total income. The\nAO held that the claim of bad-debts under section 36(1)(vii) is subject

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

65,10,683/- under section 36(1)(vii) r.w.s.36(2) of the Act.\nThe assessee also claimed an amount of Rs.81,73,55,929/- as provision for\ndoubtful debts under section 36(1)(viia)(c) of the Act at 5% of total income. The\nAO held that the claim of bad-debts under section 36(1)(vii) is subject

ADITYA BIRLA SUN LIFE AMC LIMITED,MAHARASHTRA vs. THE DEPUTY COMMISSIONER OF INCOME TAX- CIRCLE 6(1)(1), MAHARASHTRA

Bench: Shri Amit Shukla & Shri Makarand Vasant Mahadeokar1. Ita No. 6663/Mum/2025 (Assessment Year: 2017-18) 2. Ita No. 6701/Mum/2025 (Assessment Year: 2018-19) 3. Ita No. 6702/Mum/2025 (Assessment Year: 2022-23) & 4. Ita No. 6703/Mum/2025 (Assessment Year: 2023-24) Aditya Birla Sun Life Dcitcircle-6(1)(1), Amc Limited, Room No. 502, 5Th 17Th Floor, One World Vs. Floor, Aayakar Centre Tower-1, Jupiter Bhavan, M. K. Mill Compount, 841, Road, Churchgate, Senapati Bapat Marg, Mumbai-400 020 Delisle Road, S.O. Mumbai-400 013 Pan/Gir No. Aaacb6134D (Applicant) (Respondent) Assessee By Shri Ronak Doshi, Shri Shrey Agrawal & Shri Aadish Jain, Ld. Ars Revenue By Shri Surendra Mohan, Ld. Dr Date Of Hearing 27.01.2026 Date Of Pronouncement 06.02.2026

section 143(1) continued to form part of the assessed income. 65. Before the ld. CIT(A), the assessee challenged the sustained disallowance

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

1)(viii) of the Act- Rs. 55,14,65,399/- a) The learned CIT(A) erred in confirming the disallowance of deduction of Rs. 55,14,65,399/- as claimed by the Appellant under section

ICICI BANK LTD.,MUMBAI vs. THE DY CIT -2(3)(1), MUMBAI

In the result, appeal filed by the assessee is partly allowed

Bench: Shri Prashant Maharishi, Am & Shri Sandeep Singh Karhail, Jm Icici Bank Ltd. The Dy. Commissioner Of Icici Bank Towers, Income-Tax 2(3)(1) Bandra Kurla Complex, Aaykar Bhavan, Vs. 5Th Floor, Room No.552, Badra (East), Mumbai-400 051 M.K. Road, Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaaci1195H

65,62,50,000/- was upwardly revised by ₹5,82,51,214/-. ii. Disallowance under Section 14A of the Act as per Rule 8D by computing the total disallowance of ₹1

BANK OF INDIA,MUMBAI vs. ACIT-2(1)(2), 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

1)(vii) r.w.s. 36(2)(v) of the Act? (Tax Effect: Rs. 2,71,97,333/- @34.61% Rs. 8,22,59,119/-) 8. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) has erred in deleting the disallowance of interest on Perpetual Bonds as Perpetual Bonds cannot be are not borrowed

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

1)(vii) r.w.s. 36(2)(v) of the Act? (Tax Effect: Rs. 2,71,97,333/- @34.61% Rs. 8,22,59,119/-) 8. Whether on the facts and in the circumstances of the case and in law, the Ld. CIT(A) has erred in deleting the disallowance of interest on Perpetual Bonds as Perpetual Bonds cannot be are not borrowed

DY..C.I.T., BANGALORE vs. M/S STATE BANK OF MYSORE, BANGALORE

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

1)(viii) of the Act- Rs.\n55,14,65,399/-\na) The learned CIT(A) erred in confirming the disallowance of deduction of Rs.\n55,14,65,399/- as claimed by the Appellant under section

BANK OF INDIA,MUMBAI vs. THE NATIONAL FACELESS ASSESSMENT CENTRE, MUMBAI

1 to 160\nof the paper book filed by the assessee. It is noticed that assessing officer has\nspecifically asked the assessee vide notice dated 24.11.2016 to provide the detail\nof income tax reversal on distribution of unsecured perpetual securities. In this\nregard assessee has given detailed submission vide letter dated 16.12.2016\nstating that it has issued 11.4% unsecured perpetual

ACIT, MUMBAI vs. K RAHEJA CORP PRIVATE LIMITED, MUMBAI

In the result, the appeal of the Revenue is dismissed

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2020-21

65,50,231 during the year under consideration and made a suo moto disallowance of during the year under consideration and made a suo moto disallowance of during the year under consideration and made a suo moto disallowance of Rs. 1,45,32,176 under Section

BAJAJ ELECTRICALS LTD,MUMBAI vs. ADDL CIT 2(1), MUMBAI

Accordingly we remit the impugned issue back to the AO with similar directions. The grounds raised by the assessee in this regard are allowed for statistical purposes

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

section 14A r.w.r 8D and thus the grounds raised by the assessee in this regard are allowed. 13 ITA 4172/M/13-5749-5750/M/15-110- 111/M/16 Bajaj Electricals Limited Disallowance of commission expenses – Ground No.2 16. The AO during the course of assessment noticed that the assessee has paid commission of Rs. 17,06,10,525/- and that the assessee has in the original return

DCIT 2(1)(1), MUMBAI vs. BAJAJ ELECTRICALS LTD, MUMBAI

Accordingly we remit the impugned issue back to the AO with similar directions. The grounds raised by the assessee in this regard are allowed for statistical purposes

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

section 14A r.w.r 8D and thus the grounds raised by the assessee in this regard are allowed. 13 ITA 4172/M/13-5749-5750/M/15-110- 111/M/16 Bajaj Electricals Limited Disallowance of commission expenses – Ground No.2 16. The AO during the course of assessment noticed that the assessee has paid commission of Rs. 17,06,10,525/- and that the assessee has in the original return