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TMI Blog2015 (3) TMI 1026X X X X Extracts X X X X X X X X Extracts X X X X ..... 920 - ITAT PUNE]. - Once such is the nature of material before the Commissioner of Income Tax (Appeals) and the Income Tax Appellate Tribunal, then, we are of the opinion that the view taken by the Tribunal cannot be termed as perverse. The Tribunal's view is in consonance with the banking policy and the guidelines issued by the Reserve Bank of India. We further feel that a different treatment ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... vour by the Reserve Bank of India. The bank was aggrieved and dissatisfied with the exercise undertaken by the assessing officer. He made certain disallowances on the loss of shifting classified securities amounting ₹ 2,22,25,310/-. 4. The assessing officer's order was challenged before the Commissioner of Income Tax (Appeals) and the bank relied upon the circular issued by the Reserv ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ain securities which were purchased at the ruling price which was higher than their face value. The premium so paid indicates the difference between the purchase price and the face value of the security which are required to be held until maturity under the Reserve Bank of India directives. On the date of maturity, the bank is entitled to receive an amount equal to only face value. Thus, the face ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... itted that it purchased the certain securities at a price higher than the maturity value. The excess amount of premium is to be written off on proportionate basis from year to year. A sum of ₹ 70,63,042/- represents such proportionate expenditure written off in the year under consideration. Even this argument has been accepted. 6. The Tribunal in dismissing the revenue's appeal and up ..... X X X X Extracts X X X X X X X X Extracts X X X X
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