JUDGMENT :

Hrishikesh Roy, J.

1. Leave granted in SLP(C) No. 32761/2018 for analogous consideration with the related appeals.

2. The question of law to be answered in the present batch of appeals is on interpretation of Section 14A of the Income Tax Act (for short “the Act”) and the same reads as follows:

“Whether proportionate disallowance of interest paid by the banks is called for under Section 14A of Income Tax Act for investments made in tax free bonds/securities which yield tax free dividend and interest to assessee Banks when assessee had sufficient interest free own funds which were more than the investments made”

3. While common arguments have been advanced by the learned counsel for the parties, to place the legal issues in the appropriate perspective, the relevant facts are adverted from the Civil Appeal No. 9606 of 2011 (South Indian Bank Ltd. Vs. CIT, Trichur), for the purpose of this judgment.

4. The assessees are scheduled banks and in course of their banking business, they also engage in the business of investments in bonds, securities and shares which earn the assessees, interests from such securities and bonds as also dividend income on investments in shares of compani