ITAT deletes addition for interest accrued on non-performing assets

ACIT Vs Davangere District Central Co-operative Bank Ltd (ITAT Bangalore)

Introduction: The legal battle between ACIT and Davangere District Central Co-operative Bank Ltd reached its pinnacle at ITAT Bangalore. The core issue revolved around the addition made by the AO concerning interest accrued on non-performing assets (NPA). The CIT(A) stepped in, citing authoritative judgments, and ruled in favor of the bank. This article delves into the specifics of the case, the arguments presented, and the pivotal judgments that influenced the outcome.

Detailed Analysis: In the assessment years 2011-12 and 2013-14, the primary contention focused on the AO’s addition related to interest on non-performing assets. The CIT(A), drawing guidance from the esteemed decisions of the Hon’ble Apex Court in UCO Bank vs. CIT (237 ITR 889, 1999) and the Hon’ble Karnataka High Court in CIT vs. Canfin Homes Ltd. (347 ITR 0382), annulled the AO’s addition. The learned CIT(A) adhered to the established legal precedents, emphasizing the inapplicability of the AO’s stance.

The Revenue, dissatisfied with the CIT(A)’s decisions, sought redress at ITAT Bangalore. However, the ITAT, after scrutinizing the arguments, declined to intervene, upholding the CIT(A)’s reliance on the binding judgments. The core issue of interest addition on NPA remained settled in favor of the Davangere District Central Co-operative Bank Ltd.

Conclusion: In a significant victory for Davangere District Central Co-operative Bank Ltd, the ITAT Bangalore dismissed the Revenue’s appeals for the assessment years 2011-12 and 2013-14. The crux of the matter, revolving around the AO’s addition on interest accrued on non-performing assets, found resolution in the CIT(A)’s reliance on authoritative judgments. This case underscores the pivotal role of legal precedents in shaping tax dispute outcomes and reaffirms the importance of established principles in adjudication.

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