Case Law Details
Central Bank of India Vs Assessing Officer National Faceless Appeal Centre (ITAT Mumbai)
Introduction: In a significant legal battle, Central Bank of India has emerged victorious against the Assessing Officer in a dispute over the disallowance of expenditure under Section 14A of the Income Tax Act. The Income Tax Appellate Tribunal (ITAT) Mumbai’s ruling offers valuable insights into the treatment of exempt income-earning securities held as stock-in-trade.
Detailed Subheading-Wise Analysis:
1. Background of the Appeal: Central Bank of India contested an order dated 13/12/2022 issued by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi (CIT(A)). The appeal was filed for the assessment year 2019-20.
2. Section 14A Disallowance Dispute: The primary contention in this appeal revolves around the disallowance of expenditure under Section 14A of the Income Tax Act. The bank objected to a disallowance of Rs. 1911,07,68,683 under Section 14A read with Rule 8D, pertaining to income claimed as exempt under Section 10 of the Act.
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