Calcutta HC Dismisses Revenue Appeal as Section 115JB Not Apply to AY 2011-12

CIT Vs Royal Bank of Scotland N.V. (Calcutta High Court) The Calcutta High Court considered the substantial question of law: whether a nationalised banking company would be subject to the requirements of Section 115JB of the Income-tax Act, 1961. At the outset, the respondent-assessee submitted that Section 115JB was not applicable to the assessment year 2011-12 because the provision, introduced by the Finance Act, 2012, became applicable only from Assessment Year 2013-14. It was also submitted that the Royal Bank of Scotland was not a nationalised bank. Further, for the relevant assessment ye...