M/s Union Bank of India Vs. DCIT

Parties Involved

Facts Summary

The case involves appeals by M/s Union Bank of India (the assessee) and the Revenue against orders of the Commissioner of Income Tax (Appeals) / National Faceless Appeal Centre (NFAC), Delhi for Assessment Years 2016-17 and 2017-18. The assessee and the Revenue have raised various grounds of appeal concerning disallowances, taxation of certain incomes, and applicability of provisions under Section 115JB. The assessee has appealed against disallowances under Section 14A, disallowance of interest on Innovative Perpetual Debt Instruments (IPDI) Bonds, taxation of recovery of bad-debts, and applicability of Section 115JB. The Revenue has appealed against the disallowance of broken period interest, amortization of premium on Held To Maturity (HTM) securities, taxation of unrealized interest on Non-Performing Assets (NPA), deduction under Section 36(1)(viii), and disallowance on payment made to RBI for not following internal regulations.…

Legal Issues

• 1. Disallowance u/s 14A r.w.r. 8D
• 2. Disallowance of interest paid on IPDI Bonds
• 3. Taxation of recovery of bad-debts written off
• 4. Applicability of provisions of section 115JB
• 5. Broken period interest
• 6. Amortization of premium on HTM Securities

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

Similar Judgements

• Bank of India vs. Assistant Commissioner of Income Tax – 2(1)(2)

• India Infrastructure Finance Company Ltd. vs ACIT

  Delhi "G" Bench: New Delhi benchAY 2016-17Partly Allowed

• The Dakshin Dinajpur District Central Co-operative Bank Ltd. Vs. DCIT, Circle 3

• New Star System Solution Private Limited Vs. Dy. Commissioner of Income Tax

• Dhani Loans & Services Ltd. vs ACIT

  Delhi 'B' Bench benchAY 2021-22Allowed

• Income Tax Appellate Tribunal, Mumbai Bench

  Mumbai bench