BharatTax.net
SearchITATHigh CourtsSupreme CourtPhrasesAI ResearchHistory

Filters

BharatTax.net

Free search engine for ITAT (Income Tax Appellate Tribunal) judgments across all 28 benches in India.

Quick Links

  • Search Judgments
  • Browse by Bench
  • Recent Judgments

About

BharatTax provides free access to Income Tax Appellate Tribunal orders for legal research and reference.

© 2026 BharatTax.net. All rights reserved.

61 results for “capital gains”+ Section 15clear

Sorted by relevance

Mumbai5,658Delhi4,449Bangalore1,933Chennai1,547Kolkata1,234Ahmedabad1,171Jaipur902Hyderabad809Pune648Surat524Chandigarh483Indore401Karnataka367Cochin262Visakhapatnam242Raipur222Rajkot187Nagpur187Cuttack144Amritsar116Agra111Lucknow108SC87Guwahati82Calcutta79Telangana77Panaji61Dehradun53Jodhpur42Ranchi39Patna39Jabalpur25Allahabad24Kerala17Varanasi12Rajasthan10Orissa7Punjab & Haryana4A.K. SIKRI ROHINTON FALI NARIMAN2Andhra Pradesh2Gauhati2A.K. SIKRI N.V. RAMANA1ASHOK BHAN DALVEER BHANDARI1ANIL R. DAVE SHIVA KIRTI SINGH1K.S. RADHAKRISHNAN A.K. SIKRI1MADAN B. LOKUR S.A. BOBDE1D.K. JAIN JAGDISH SINGH KHEHAR1

Key Topics

Section 143(3)34Condonation of Delay29Section 80P(2)(a)27Disallowance24Section 14A20Deduction19Section 26317Section 80I16Addition to Income16

SOCIEADADE DE FOMENTO INDL. PVT. LTD.,MARGAO vs. JOINT COMMISSIONER OF INCOME TAX, MARGAO RANGE, MARGAO

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

ITA 105/PAN/2018[2010-11]Status: DisposedITAT Panaji12 Sept 2022AY 2010-11

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawal

For Appellant: Sh. Nishant Thakkar, AdvocateFor Respondent: Sh. Ranjan Kumar, CIT-DR
Section 143(1)Section 143(2)Section 14A

section 143(3) of the I.T. Act, 1961. Further, the investment made in shares of Sesa Goa Ltd., as is evident from the audited books of account is out of surplus money only and no borrowed funds were utilized. The assessee-company purchased 3,38,03,812 equity shares of M/s. Sesa

ACIT, CENTRAL CIRCLE, PANAJI vs. M/S SOCIADADE DE FOMENTO INDUSTRIAL P. LTD, MARGAO

Showing 1–20 of 61 · Page 1 of 4

Section 80P15
Section 143(2)10
Section 80P(2)(d)9

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

ITA 116/PAN/2018[2010-11]Status: DisposedITAT Panaji12 Sept 2022AY 2010-11

Bench: Shri Chandra Mohan Garg & Shri Girish Agrawal

For Appellant: Sh. Nishant Thakkar, AdvocateFor Respondent: Sh. Ranjan Kumar, CIT-DR
Section 143(1)Section 143(2)Section 14A

section 143(3) of the I.T. Act, 1961. Further, the investment made in shares of Sesa Goa Ltd., as is evident from the audited books of account is out of surplus money only and no borrowed funds were utilized. The assessee-company purchased 3,38,03,812 equity shares of M/s. Sesa

VIJESH VITHAL TALAULICAR,PANAJI vs. ACIT, CIRCLE - 1(1), PANAJI

In the result, appeal of the assessee is allowed in terms of our aforesaid observations

ITA 230/PAN/2017[2010-11]Status: DisposedITAT Panaji31 Mar 2022AY 2010-11

Bench: Shri Ravish Sood & Shri Jamlappa D Battullआयकर अपील सं. / Ita No. 230/Pan/2017 "नधा"रण वष" / Assessment Year : 2010-11 Shri Vijesh Vithal Talaulicar Shri Ramnath Sadan, Dr. Dada Vaidya Road, Panaji, Goa Pan : Aaxpt9647D .......अपीलाथ" / Appellant बनाम / V/S. The Asst. Commissioner Of Income Tax, Circle-1(1), Panaji. ……""यथ" / Respondent

For Appellant: Shri D.E. Robinson, ARFor Respondent: Shri Sourabh Nayak, Sr. DR
Section 143(2)Section 143(3)

gain”, as contemplated in sub-section (14) of Section 2 of the Act, we find that the same reads as under (relevant extract):- “(14) [“Capital asset” means- (a) Property of any kind held by an assessee, whether or not connected with his business or profession; (b) any securities held by a Foreign Institutional Investor which has invested in such securities

BANDEKAR BROTHERS PRIVATE LIMITED,VASCO-DA-GAMA, GOA vs. ASSISTANT COMMISSIONER OF INCOME TAX, PANAJI, GOA

The appeal of the assessee is PARTLY ALLOWED in aforestated terms

ITA 38/PAN/2025[2013-14]Status: DisposedITAT Panaji11 Feb 2026AY 2013-14

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshaliassessment Years: 2013-14 Bandekar Brothers Pvt. Ltd. Post Box No. 11, Suvarna Bandekar Bldg., Swatantra Path, Vasco-Da-Gama Goa-403802 Pan: Aaacb5502B . . . . . . . Appellant V/S Asstt. Commissioner Of Income Tax, Circle-2(1), Panaji, Goa. . . . . . . . Respondent Represented Assessee By: Mr Pramod & Mr Shriniwas Deshpande [‘Ld. Ar’] Revenue By: Mr M Satish & Mr Renga Rajan [‘Ld. Dr’] Date Of Conclusive Hearing : 12/01/2026 Date Of Pronouncement : 11/02/2026 Order Per G. D. Padmahshali; This Assessee’S Appeal Filed U/S 253(1) Of The Income-

For Appellant: Mr Pramod & Mr Shriniwas Deshpande [‘Ld. AR’]For Respondent: Mr M Satish & Mr Renga Rajan [‘Ld. DR’]
Section 143(1)Section 143(2)Section 143(3)Section 14ASection 2(14)Section 246ASection 250Section 253(1)Section 37(1)

gains under the provisions of the Act when transferred. Once the nature & character of transaction is established as capital acquisition, then; (a) the mode/nomenclature of payment in acquiring such capital asset, (b) the frequency of payment such as annual, term basis or onetime etc., and (c) the stage of discharge of payment towards viz; first instance/grant of licence

M/S R. S. SHETYE & BROS,PANAJI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE -1(1), PANAJI

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

ITA 37/PAN/2023[2016-17]Status: DisposedITAT Panaji27 Feb 2026AY 2016-17

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. No.37/Pan/2023 (A.Y.2016-17) R.S.Shetye & Bros, Vs Acit 1(1), Flat.No.14, 1 St Floor, Aaykar Bhavan, . Trionara Apartments, Edc, Patto, New Muncipal Market, Panjim Panaji- Goa-403001. Goa-403001. Pan .No.Aabfr9785N (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent)

Section 3

gains and such expenditure incurred for acquiring such lease hold right including expenditure towards renewal of mining lease is a capital expenditure. The Ld.AR contentions are that the expenditure of payment of stamp duty and registrations charges are legal expenses in connection with the renewal of lease and is allowable as revenue expenditure. The Ld.AR highlighted the receipt of “sale

MAHENDRA PURUSHOTTAM NAIK GAUNEKAR,PANAJI vs. INCOME TAX OFFICER, PANAJI

Accordingly. The ground thus stands allowed

ITA 12/PAN/2024[2016-17]Status: DisposedITAT Panaji01 Jul 2025AY 2016-17

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Rahul Sarda [‘Ld. AR’]For Respondent: Mr Capt. Pradeep Arya [‘Ld. DR’]
Section 143(2)Section 147Section 148Section 250Section 253(1)Section 50CSection 50C(1)

capital gains (Long Term) of Rs. 2,93,33,256 being the difference between the stamp duty value of Rs. 14,32,37,500 adopted by him and actual sale consideration of Rs. 11,39,04,244 although it was legally impermissible for the assessing officer to adopt the above stamp duty value

GUALA CLOSURES (INDIA) PVT. LTD.,PANAJI vs. THE PRINCIPAL COMMISSIONER OF INCOME TAX, PANAJI., SELECT CITY

Appeal is dismissed in above terms

ITA 205/PAN/2019[2012-13]Status: DisposedITAT Panaji13 Oct 2023AY 2012-13

Bench: Shri Satbeer Singh Godara & Dr. Dipak Ripote

For Appellant: Shri Ketan VedFor Respondent: Shri P.S. Shivshankar, CIT-DR
Section 143(3)Section 144(3)Section 144CSection 253Section 263Section 4

capital or revenue. The 'once for all' payment test is also inconclusive. What is relevant is the purpose of the outlay and its intended object and effect, considered in a commonsense way having regard to the business realities." (p. 379) 8 ITA.No.205/PAN./2019 In the case of this assessee, it is found that the claim of expenses under

SONALI MAHENDRA NAIK GAUNEKAR,PANAJI vs. INCOME TAX OFFICER, WARD - 1(1), PANAJI

The appeal of the assessee is partly allowed for statistical purpose

ITA 313/PAN/2025[2016-17]Status: DisposedITAT Panaji28 Oct 2025AY 2016-17

Bench: Hon’Ble Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

For Appellant: Mr Rahul Sarda [‘Ld. AR’]For Respondent: Mr Renga Rajan [‘Ld. DR’]
Section 147Section 148Section 250Section 253(1)Section 263Section 50C

capital gain of ₹2,93,33,256/- to tax as undisclosed income vide an assessment order dt. 29/09/2021 framed u/s 147 of the Act. Subsequently, the Ld. PCIT invoked the provisions of section 263 and by order dt. 19/04/2024 set-aside the former order for fresh assessment for Ld. AO’s failure to conduct inquiry. ITAT-Panaji Page

SHREE MAHILA CREDIT SOUHARD SAHAKARI SANGH NIYAMIT,BELAGAVI vs. ITO WARD 1 BELAGAVI, BELAGAVI

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 116/PAN/2024[2017-18]Status: DisposedITAT Panaji13 Feb 2026AY 2017-18

Bench: Shri Pavan Kumar Gadale & Shri G D Padmahshalii T A. No.116/Pan/2024 (A.Y. 2017-18) Shree Mahila Credit Souhard Vs Ito-Ward-2, Sahakari Sangh Niyamit, Feroj Khimjibhai Cpx, . Shop.No.3, Maruti Complex, Civil Hospital Road 2 Nd Railway Gate, Tilakwadi, Belagavi-590001. Belgaum-500006, Karnataka. Karnataka. . Pan .No. Aabas9244A (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) Assessee By Shri.Pramod Y Vaidya.Ar Revenue By Smt.Rijula Uniyal.Sr.Dr सुनवाई की तारीख/Date Of Hearing 09.02.2026 घोषणा की तारीख/Date Of Pronouncement 13.02.2026 Order Per Pavan Kumar Gadale, Jm: The Appeal Is Filed By The Assesse Against The Order Of The Nfac/Cit(A) Passed U/Sec 143(3) & U/Sec 250 Of The Act. The Assessee Has Raised The Grounds Of Appeal Challenging The Order Of The Cit(A) Partially Sustaining The Denial Of Claim Of Deduction U/Sec80P(2)(A)(I) Of The Act Made By The Assessing Officer & Without Prejudice Alternate Relief U/Sec80P(2)(D) Of The Act & Sustaining Denial Of Deduction Of Interest On Income Tax Refund Under Section 80P(2)(A)(I) Of The Act.

Section 80P(2)(a)Section 80P(2)(d)

capital available in the process of carrying out providing credit facilities which is the business of the assessee. As per specific clause of the governing law and bye laws the amounts are invested in Co-operative Credit societies, Co-operative Banks and Scheduled Banks. Investments in scheduled banks are made on account of commercial expediency of quick liquidity whenever

SHRI LALJI PURSHOTTAM DABHOYYA PATEL,ALTINHO vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 1(1), PANAJI

In the result, the appeal is allowed

ITA 339/PAN/2018[2007-08]Status: DisposedITAT Panaji17 Aug 2022AY 2007-08

Bench: Shri C.M. Garg & Shri Girish Agrawalassessment Year: 2006-07 Ito, Vs. Shri Lalji Purshottam Dabhoyya Ward 1(1), Patel, Panaji, Hill View, Althinho, Goa. Panaji, Goa- 403 001. Pan: Abapd1169Q Assessment Year: 2007-08 Shri Lalji Purshottam Vs. Acit, Dabhoyya Patel, Circle -1(1), Hill View, Althinho, Panaji, Panaji, Goa- 403 001. Goa. Pan: Abapd1169Q (Appellant) (Respondent) Assessee By : Shri Jitendra Jain, Advocate Revenue By : Shri Mayur Kamble, Sr. Dr Date Of Hearing : 15.06.2022 Date Of Pronouncement : 17.08.2022 Order Per C.M. Garg, Jm: This Appeal Has Been Filed By The Assessee Against The Order Of The Cit(A), Panaji-1, Dated 31.05.2018 For Assessment Year 2007-08. Ita Nos.361 & 339/Pan/2018 2. Facts Of The Case, In Brief, Are That The Assessee Is A Civil Contractor Carrying On The Business At Panaji, Goa. The Assessee Filed His Return Of Income Declaring The Total Income At Rs.9,02,333/-. The Ao Completed The Assessment U/S 143(3) Of The Act By Making The Following Additions:- I) Unexplained Cash Credit - Rs.27,33,000.00 Ii) Unconfirmed Creditors - Rs. 6,30,000.00 Iii) Depreciation Disallowance - Rs. 1,03,697.00

For Appellant: Shri Jitendra Jain, AdvocateFor Respondent: Shri Mayur Kamble, Sr. DR
Section 133ASection 143(3)Section 271Section 271(1)(c)Section 274Section 45

capital assets i.e. construction area is received by it against the transfer of land under the Joint Development Agreement. However, the Amendment of sec. 45(5A) of the Income Tax Act, 1961 cannot be applied retrospectively for Joint Development Agreement with area- sharing arrangement entered prior to AY 2018-19, the amendment status is effective from the said Asst. Year

INCOME TAX OFFICER, WARD - 1(1), PANAJI vs. SHRI LALJI PURUSHOTTAM BABHOYYA PATEL, ALTINHO

In the result, the appeal is allowed

ITA 361/PAN/2018[2006-07]Status: DisposedITAT Panaji17 Aug 2022AY 2006-07

Bench: Shri C.M. Garg & Shri Girish Agrawalassessment Year: 2006-07 Ito, Vs. Shri Lalji Purshottam Dabhoyya Ward 1(1), Patel, Panaji, Hill View, Althinho, Goa. Panaji, Goa- 403 001. Pan: Abapd1169Q Assessment Year: 2006-07 Shri Lalji Purshottam Vs. Acit, Dabhoyya Patel, Circle -1(1), Hill View, Althinho, Panaji, Panaji, Goa- 403 001. Goa. Pan: Abapd1169Q (Appellant) (Respondent) Assessee By : Shri Jitendra Jain, Advocate Revenue By : Shri Mayur Kamble, Sr. Dr Date Of Hearing : 15.06.2022 Date Of Pronouncement : 17.08.2022 Order Per C.M. Garg, Jm: This Appeal Has Been Filed By The Assessee Against The Order Of The Cit(A), Panaji-1, Dated 31.05.2018 For Assessment Year 2007-08. Ita Nos.361 & 339/Pan/2018 2. Facts Of The Case, In Brief, Are That The Assessee Is A Civil Contractor Carrying On The Business At Panaji, Goa. The Assessee Filed His Return Of Income Declaring The Total Income At Rs.9,02,333/-. The Ao Completed The Assessment U/S 143(3) Of The Act By Making The Following Additions:- I) Unexplained Cash Credit - Rs.27,33,000.00 Ii) Unconfirmed Creditors - Rs. 6,30,000.00 Iii) Depreciation Disallowance - Rs. 1,03,697.00

For Appellant: Shri Jitendra Jain, AdvocateFor Respondent: Shri Mayur Kamble, Sr. DR
Section 133ASection 143(3)Section 271Section 271(1)(c)Section 274Section 45

capital assets i.e. construction area is received by it against the transfer of land under the Joint Development Agreement. However, the Amendment of sec. 45(5A) of the Income Tax Act, 1961 cannot be applied retrospectively for Joint Development Agreement with area- sharing arrangement entered prior to AY 2018-19, the amendment status is effective from the said Asst. Year

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), PANAJI, AYAKAR BHAWAN vs. VPK URBAN COOPERATIVE CREDIT SOCIETY , VPK BHAWAN

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 252/PAN/2024[2015-16]Status: DisposedITAT Panaji28 Nov 2025AY 2015-16

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

15 of 36 Akshaya Co-Op credit society Limited & others. assessee on its investments with a co-operative bank would be eligible for claim of deduction under Sec. 80P(2)(d) of the Act. Still further, we find that the CBDT Circular No. 14, dated 28.12.2006, also makes it clear beyond any scope of doubt that the purpose behind enactment

THE ADARSH MULTIPURPOSE CO-OPERATIVE SOCIETY,BELAGAVI vs. INCOME TAX OFFICER WARD 1-(2) , BELAGAVI, BELAGAVI

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 245/PAN/2024[2016-17]Status: DisposedITAT Panaji28 Nov 2025AY 2016-17

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

15 of 36 Akshaya Co-Op credit society Limited & others. assessee on its investments with a co-operative bank would be eligible for claim of deduction under Sec. 80P(2)(d) of the Act. Still further, we find that the CBDT Circular No. 14, dated 28.12.2006, also makes it clear beyond any scope of doubt that the purpose behind enactment

KUMTA ADIKE MARATA SOPUHARDA SAHAKARI SANGH NIYAMIT,KUMTA vs. INCOME TAX OFFICER, WARD - 2, KARWAR

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 153/PAN/2024[2020-21]Status: DisposedITAT Panaji28 Nov 2025AY 2020-21

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

15 of 36 Akshaya Co-Op credit society Limited & others. assessee on its investments with a co-operative bank would be eligible for claim of deduction under Sec. 80P(2)(d) of the Act. Still further, we find that the CBDT Circular No. 14, dated 28.12.2006, also makes it clear beyond any scope of doubt that the purpose behind enactment

SAMARTH URBAN CO-OPERATIVE CREDIT SOCIETY LTD,BELGAUM vs. PR. COMMISSIONER OF INCOME TAX , BELAGAVI

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 152/PAN/2024[2020-21]Status: DisposedITAT Panaji28 Nov 2025AY 2020-21

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

15 of 36 Akshaya Co-Op credit society Limited & others. assessee on its investments with a co-operative bank would be eligible for claim of deduction under Sec. 80P(2)(d) of the Act. Still further, we find that the CBDT Circular No. 14, dated 28.12.2006, also makes it clear beyond any scope of doubt that the purpose behind enactment

PRATHAMIK KRISHI PATTIN SAHAKARI SANGH NIYAMIT LTD BHOJ,BHOJ vs. INCOME TAX OFFICER, WARD-1, NIPANI

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 272/PAN/2024[2017-18]Status: DisposedITAT Panaji28 Nov 2025AY 2017-18

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

15 of 36 Akshaya Co-Op credit society Limited & others. assessee on its investments with a co-operative bank would be eligible for claim of deduction under Sec. 80P(2)(d) of the Act. Still further, we find that the CBDT Circular No. 14, dated 28.12.2006, also makes it clear beyond any scope of doubt that the purpose behind enactment

SHRI BASAVESHWAR URBAN CO OPERATIVE CREDIT SOCIETY LTD,BELAGAVI vs. INCOME TAX OFFICER NATIONAL E ASSESSMENT, BELAGAVI

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 180/PAN/2024[2020-2021]Status: DisposedITAT Panaji28 Nov 2025AY 2020-2021

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

15 of 36 Akshaya Co-Op credit society Limited & others. assessee on its investments with a co-operative bank would be eligible for claim of deduction under Sec. 80P(2)(d) of the Act. Still further, we find that the CBDT Circular No. 14, dated 28.12.2006, also makes it clear beyond any scope of doubt that the purpose behind enactment

BASAV SOUHARDA CREDIT SAHAKARI NIYAMIT BAILHONGAL,BAILHONGALA vs. INCOME TAX OFFICER NATIONAL E ASSESSMENT CENTER, BELAGAVI

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 190/PAN/2024[2020-2021]Status: DisposedITAT Panaji28 Nov 2025AY 2020-2021

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

15 of 36 Akshaya Co-Op credit society Limited & others. assessee on its investments with a co-operative bank would be eligible for claim of deduction under Sec. 80P(2)(d) of the Act. Still further, we find that the CBDT Circular No. 14, dated 28.12.2006, also makes it clear beyond any scope of doubt that the purpose behind enactment

SHRI BASAVESHWAR URBAN CO OPERATIVE CREDIT SOCIETY LIMITED,BELAGAVI vs. INCOME TAX OFFICER NATIONAL E ASSESSMENT CENTRE, BELAGAVI

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 179/PAN/2024[2018-2019]Status: DisposedITAT Panaji28 Nov 2025AY 2018-2019

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

15 of 36 Akshaya Co-Op credit society Limited & others. assessee on its investments with a co-operative bank would be eligible for claim of deduction under Sec. 80P(2)(d) of the Act. Still further, we find that the CBDT Circular No. 14, dated 28.12.2006, also makes it clear beyond any scope of doubt that the purpose behind enactment

VPK URBAN CO-OPERATIVE CREDIT SOCIETY,MARDOL, PONDA vs. INCOME TAX OFFICER, PANAJI

In the result, the appeal filed by the revenue is dismissed and twenty eight appeals filed by the assessee are partly allowed for statistical purpose in aforestated terms

ITA 255/PAN/2024[2015-16]Status: DisposedITAT Panaji28 Nov 2025AY 2015-16

Bench: Shri Pavan Kumar Gadale & Shri G. D. Padmahshali

15 of 36 Akshaya Co-Op credit society Limited & others. assessee on its investments with a co-operative bank would be eligible for claim of deduction under Sec. 80P(2)(d) of the Act. Still further, we find that the CBDT Circular No. 14, dated 28.12.2006, also makes it clear beyond any scope of doubt that the purpose behind enactment