2023 (12) TMI 1375

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....dvocate)- Ld.AR For the Respondent : Shri J.Premanand (CIT)-Ld. Sr. DR ORDER MANOJ KUMAR AGGARWAL (ACCOUNTANT MEMBER) 1. The sole grievance of the assessee in the captioned appeal is confirmation of certain disallowance u/s 14A. Though the assessee has raised another ground relating to disallowance of provision on security receipts while computing Book Profits, however, Ld. AR submitte....

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.... computed disallowance of Rs. 28.25 Crores and added the differential of Rs. 27.07 Corers to the income of the assessee while computing income under normal provisions as well as while computing Book Profits u/s 115JB. 4. The Ld. CIT(A) concurred with assessee's submissions that only exempt yielding investments are to be considered while computing the said disallowance. However, Ld. CIT(A) uphel....

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....an 48/289 ITR 6 (SC), wherein this Court had held that investments made by a banking concern is part of their banking business. Hence the income earned through such investments would fall under the head Profits & Gains of business. The Punjab and Haryana High Court, in the case of Pr CIT v. State Bank of Patiala [2017] 88 taxmann.com 667/393 ITR 476 (Punj. & Har.), while adverting to the CBDT Circ....