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of <h1>SC Dismisses Revenue's Appeal, Upholds Bombay HC Ruling on Salary Apportionment and Sticky Loan Interest for 1982-83.</h1> <h3>Commissioner of Income Tax, Bombay City-III Versus Bank of America</h3> In the SC of India case regarding the assessment year 1982-83, the Revenue's appeal against the Bombay HC's decision was dismissed. The SC affirmed the ... - In the Supreme Court of India case citation 2008 (8) TMI 1047 - SC, the Revenue appealed against the Bombay High Court's decision regarding the assessment year 1982-83. The High Court had ruled in favor of the assessee on three questions:1. Apportionment of Salary and Perquisites: The High Court held that salary and perquisites paid by the assessee bank to its employees should be apportioned under Section 21 of the Income Tax Act, applying Section 40A(5) only to the portion considered under Section 28. This decision was affirmed by the Supreme Court, referencing its order in Civil Appeal No. 1533 of 2006.2. Interest on Sticky Loans: The High Court, following the Supreme Court's judgment in UCO Bank vs. CIT (237 ITR 889), directed the assessing officer to determine the interest includible in total income on sticky loans based on a CBDT Circular. The Supreme Court upheld this decision, ruling in favor of the assessee.3. General Question: The Court deemed this question as general and not requiring an answer.The Supreme Court dismissed the appeal, with each party bearing their own costs.
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