आयकर अपीलीय अधिकरण, ‘ए’ न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, CHENNAI श्री एस एस विश्वनेत्र रवि, न्याविक सदस्य एवं श्री एस. आर. रघुनाथा, लेखा सदस्य के समक्ष BEFORE SHRI S.S. VISWANETHRA RAVI, JUDICIAL MEMBER AND SHRI S.R. RAGHUNATHA, ACCOUNTANT MEMBER आयकर अपील सं./ITA Nos.: 1478 & 1479/Chny/2025 धनिाारण वर्ा / Assessment Year: 2020-21 and 2021-22 M/s. City Union Bank, PCIT No. 148-149, T.S.R Big Street, vs. Madurai – 1.

Kumbakonam – 621 001.

Tamil Nadu.

[PAN: AAACC-1287-E]

(अपीलाथी/Appellant) (प्रत्यथी/Respondent)

अपीलाथी की ओर से/Appellant by : Mr. S. Ananthan, CA and Ms. R. Lalitha, CA प्रत्यथी की ओर से/Respondent by : Ms. E. Pavuna Sundari, CIT.

सुनवाई की तारीख/Date of Hearing : 28.08.2025 घोर्णा की तारीख/Date of Pronouncement : 09.09.2025 आदेश /O R D E R PER S.R.RAGHUNATHA, AM :

The captioned appeals are filed by the assessee against the order of the learned Principal Commissioner of Income Tax, Madurai – 1, [In short “the Ld.PCIT”] for the A.Ys. 2020-21 & 2021-22 respectively. Since the issues involved in both the appeals are identical, they are disposed of by a common order.

2. The grounds raised by the assessee for A.Y. 2020-21 are as follows:

1. The order of the Learned Principal Commissioner of Income Tax, Madurai-1 is against the law & contrary to the facts & circumstances that are prevalent in the case of the Appellant.

1.1. The order of the Learned Principal Commissioner of Income Tax is against the provisions of Section 263 of the Income Tax Act, 1961.

2. The Learned Principal Commissioner erred in invoking the provisions of Section

263 of the Income Tax Act, 1961 and setting aside the Assessment order.

2.1. The Learned Principal Commissioner failed to appreciate the fact that there is no error in the order relating to the issues covered by the notice u/s 263.

2.2. The Learned Principal Commissioner erred in holding that the assessing officer has failed to cause enquiry in the assessment proceedings before completion of assessment.

2.3. The Learned Principal Commissioner failed to appreciate the fact that the assessing officer has called details of the issues involved during the course of assessment proceedings and finalized assessment.

2.4. The Learned Principal Commissioner failed to appreciate that the issues which have been set aside were allowed by appellate forums and latest decisions of the ITAT in appellant own case and the learned Assessing Officer has adopted one of the possible views.

2.5. The Learned Principal Commissioner erred in setting aside the order without pointing out any error in the order.

3. Without prejudice to Ground no 2, the Learned Principal Commissioner erred in setting aside the order in toto for making a fresh assessment instead of setting aside the order partially relating to those issues covered by the 263 proceedings.

4. The Learned Principal Commissioner erred in setting aside the issue of deduction allowed u/s 36(1)(vii) of the Income Tax Act, 1961.

4.1. The Learned Principal Commissioner erred in holding that an amount Rs

228.78 crs has been claim excessively u/s 36(1)(vii) of the Act.

4.2. The Learned Principal Commissioner failed to consider the fact that the issues have been settled by the Hon’ble Supreme court and latest decisions of the ITAT in appellant’s own case.

4.3. The Learned Principal Commissioner failed to appreciate the fact that the issue was verified by the learned Assessing Officer.

5. The Learned Principal Commissioner erred in holding that the amount of Rs 38.31 crs allowed by the assessing officer is erroneous and prejudicial to the interest of the revenue.

5.1. The Learned Principal Commissioner erred in not considering the fact the issue has been decided by various appellate forums in favour of the appellant.

5.2. The Learned Principal Commissioner failed to appreciate the fact that the bank claimed ESOS expenses and on the same amount, the bank applied TDS on each employees by treating it as perquisite u/s 17(2) of the Act.

5.3. The Learned Principal Co