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2025 Supreme(Online)(ITAT) 6831

INCOME TAX APPELLATE TRIBUNAL (BANGALORE BENCH)
Shri Waseem Ahmed, ACJ, Shri Keshav Dubey, J
The Asst. Commissioner of Income Tax – Appellant
Versus
Canara Bank (erstwhile Circle – 2(2)(1), Syndicate Bank) – Respondent


Advocates:
For the Appellants/Petitioners: Shri Vishal Bhat - CA
For the Respondents: Dr. Manjunath Karkihalli, CIT (DR)

Table of Content
1. overview of jurisdiction and background information. (Para 1 , 2)
2. arguments about mat applicability to banking company. (Para 3)
3. reasoning and analysis by the court to support conclusions. (Para 5 , 8)
4. final decision on the appeals dismissed. (Para 6 , 9)
5. key determination on the non-applicability of section 115jb. (Para 7)

ORDER

PER WASEEM AHMED, ACCOUNTANT MEMBER:

This set of appeals is filed by the Revenue against the order passed by the NFAC vide order dated 29-03-2025 for the assessment years 2013-14 to 2017-18.

ITA No. 1495/Bang/2025 for the AY 2013-14

2. The only interconnected issued raised by the Revenue is that the ld. CIT(A) erred in holding that the provisions of sec. 115JB of the Act are not applicable to the assessee being a Banking Company.

3. At the outset, the ld. Counsel for the assessee before us submitted that the assessee is a bank and therefore, it is outside the purview of MAT provision specified u/s 115JB of the Act. The ld. AR in support of his contention relied on the order of this Tribunal in its own case for the assessment years 2013-14 and 2014-15 vide ITA Nos. 937 and 938/Bang/2024 order dated 16/10/2024 reported in 2025/TIOL/116.

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