IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SMT. BEENA PILLAI (JUDICIAL MEMBER)

&

SHRI JAGADISH (ACCOUNTANT MEMBER)

Assessment Year: 2010-11 State Bank of India Vs. The Assistant Commissioner of Financial Reporting & Taxation Income-tax, Circle-2(2)(1), Dept. Mumbai

3^rd Floor, Corporate Centre Madam Cama Road Nariman Point Mumbai - 400021 [PAN: AAACS8577K]

(Appellant) (Respondent)

I.T.A. No. 3882/Mum/2017 Assessment Year: 2010-11 The Assistant Commissioner Vs. State Bank of India of Income-tax, Circle-2(2)(1), Financial Reporting & Taxation Mumbai Dept.

3rd Floor, Corporate Centre Madam Cama Road Nariman Point Mumbai - 400021 [PAN: AAACS8577K]

(Appellant) (Respondent)

Assessee by Shri Ketan Ved/Shri Ninad Patade, A/Rs Revenue by Shri P.C. Chhotaray, Spl. Counsel Date of Hearing 09.02.2026 Date of Pronouncement 21.04.2026 ORDER Per Bench:

Present cross-appeals arise out of the order dated 21/03/2017 passed by Learned Commissioner of Income-tax (Appeals)-5, Mumbai [hereinafter “Ld.CIT(A)”], for Assessment Year 2010-11 on following grounds of appeal:- Assessee’s Appeal:

“The appellant objects to the order of the Commissioner of Income-tax (Appeals) - 5, Mumbai [CIT(A)] dated 21 March 2017 for the aforesaid assessment year on the following among other grounds:

1. Provision for pension of Rs. 1972,64,00,000 The leaned CIT(A) erred in upholding the action of the Assessing Officer in disallowing the appellant’s claim in respect of provision for pension amounting to Rs. 1972,64,00,000.

2. Depreciation on matured securities of Rs. 13,90,80,321 The learned CIT(A) erred in confirming the disallowance of Rs. 13,90,80,321 in respect of depreciation on matured securities which had fallen due for redemption during year ended 31 March 2010 but redemption proceeds were not received.

3. Disallowance under section 14A

3.1. The learned CIT(A) erred in not specifically directing the Assessing Officer to compute disallowance under section 14A in respect to foreign currency loans, tax-free bonds, shares (other than strategic investments) and units of mutual funds as nil, as these investments of the appellant are stock-in-trade.

3.2. The learned CIT(A) erred in holding that the disallowance shall not be below the amount disallowed by the appellant himself in the computation of total income.

3.3. Without prejudice to the above, the learned CIT(A) erred in not appreciating that assets not yielding any exempt income during the year should not be considered for the purpose of computing disallowance under section 14A.

4. Depreciation on leased assets of Rs. 4,02,40,203 The learned CIT(A) erred in upholding the action of the Assessing Officer in disallowing the appellant’s claim in respect of depreciation of Rs.

4,02,40,203 on leased assets.

5. Deduction under section 36(1)(vii) of Rs. 1557,54,51,504

5.1. The learned CIT(A) erred in not allowing deduction of Rs. 1557,54,51,504 under section 36(1)(vii) being the amount of bad debts written-off (other than in respect of rural advances).

5.2. The learned CIT(A) erred in relying on explanation 2 to section 36(1) as inserted by the Finance Act, 2013 which is applicable from assessment years 2014-15 onwards.

6. Provision for other employee benefits of Rs. 47,04,00,000

6.1. The learned CIT(A) erred in not allowing a deduction of Rs. 47,04,00,000 in respect of provision for other employee benefits comprising of leave travel & home travel concession, sick leave and casual leave.

6.2. The learned CIT(A) erred in holding that the aforesaid provisions were covered under clause (f) of section 43B without appreciating that the provision in respect of casual leave and sick leave is not encashable. 7. Provision for privilege leave encashment of Rs. 107,54,00,000 The learned CIT(A) erred in not allowing the deduction of Rs.

107,54,00,000 in respect of provision for privilege leave encashment.

8. Depreciation on securities The learned CIT(A) erred in upholding the action of the Assessing Officer in reducing depreciation / taxing ap