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Issues Involved:
1. Charging to tax interest on securities accrued but not due. 2. Taxation of appreciation in value of capital invested in foreign branch repatriated to India. 3. Disallowance of depreciation on building. 4. Disallowance of entertainment expenses. 5. Addition of appreciation in value of balance of foreign branches account in head office books. 6. Disallowance of arrears of salary payable to staff. 7. Disallowance of loss on revaluation of securities. 8. Disallowance of expenditure on Wills World Cup. 9. Various other grounds including deduction u/s 43B, taxability of write-back of excess provision towards bad debts, deduction u/s 80G, levy of additional tax, non-taxability of rebated interest, and deduction u/s 80M. Summary: 1. Charging to Tax Interest on Securities Accrued but Not Due: The assessee contested the addition of Rs. 26,25,37,472/- for AY 1994-95 and Rs. 71,59,42,553/- for AY 1995-96 made by the Assessing Officer (AO) and confirmed by the CIT(A). The Tribunal found that the assessee failed to explain the exclusion of interest income that became legally due in the relevant years. The Tribunal upheld the AO's addition, dismissing the assessee's ground of appeal. 2. Taxation of Appreciation in Value of Capital Invested in Foreign Branch Repatriated to India: The AO added Rs. 1,31,59,65,267/- to the income of the assessee, which was confirmed by the CIT(A). The Tribunal upheld this decision, stating that the exchange gain was realized and not notional, and thus taxable as revenue receipt. 3. Disallowance of Depreciation on Building: The assessee's claim for depreciation on building was disallowed by the AO and confirmed by the CIT(A). The Tribunal upheld the disallowance based on its earlier decision in the assessee's case for AY 1997-98. 4. Disallowance of Entertainment Expenses: The AO disallowed entertainment expenses of Rs. 6,86,572/- for AY 1994-95, Rs. 6,52,612/- for AY 1995-96, and Rs. 7,23,780/- for AY 1996-97, which was confirmed by the CIT(A). The Tribunal upheld the disallowance, following its earlier decision in the assessee's case for AY 1997-98. 5. Addition of Appreciation in Value of Balance of Foreign Branches Account in Head Office Books: The AO added Rs. 47,05,41,973/- to the income of the assessee, which was confirmed by the CIT(A). The Tribunal remanded the matter back to the AO for fresh adjudication after verification of facts. 6. Disallowance of Arrears of Salary Payable to Staff: The AO disallowed the assessee's claim of Rs. 53,46,21,347/- for wage arrears, which was confirmed by the CIT(A). The Tribunal remanded the issue back to the AO for fresh adjudication considering the bipartite agreement dated 14.2.1995. 7. Disallowance of Loss on Revaluation of Securities: The AO disallowed the loss of Rs. 104,43,71,688/- on revaluation of securities, which was confirmed by the CIT(A). The Tribunal allowed the assessee's appeal, following the decision of the Hon'ble Madras High Court in CIT vs Karur Vysya Bank Ltd. 8. Disallowance of Expenditure on Wills World Cup: The AO disallowed Rs. 98,05,001/- of the total expenditure of Rs. 1,58,05,001/- incurred on Wills World Cup, which was confirmed by the CIT(A). The Tribunal allowed the assessee's appeal, stating the entire expenditure is revenue in nature and should be allowed as deduction. 9. Various Other Grounds: - Deduction u/s 43B: The Tribunal dismissed the ground as not pressed. - Taxability of Write-back of Excess Provision towards Bad Debts: The Tribunal dismissed the ground as not pressed. - Deduction u/s 80G: The Tribunal dismissed the ground as not pressed. - Levy of Additional Tax: The Tribunal dismissed the ground as not pressed. - Non-taxability of Rebated Interest: The Tribunal remanded the issue back to the AO for fresh adjudication. - Deduction u/s 80M: The Tribunal dismissed the ground as not pressed. Conclusion: The Tribunal dismissed the appeal for AY 1994-95, partly allowed the appeal for AY 1995-96 for statistical purposes, and partly allowed the appeal for AY 1996-97.
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