2025 (7) TMI 516

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....er. 3. For the sake of convenience and clarity the facts relevant to the appeal bearing ITA No. 529/Coch/2023 for AY 2000-01 are stated herein. 4. Brief facts of the case are that the appellant is a private scheduled bank. The return of income for AY 2000-01 was filed on 28.11.2000 declaring income of Rs. 2,30,87,400/- and the same was revised at an income of Rs. 2,61,44,880/-. Subsequently, reassessment was completed vide order dated 31.01.2003 passed u/s. 143(3) r.w.s. 147 of the Income Tax Act, 1961 (the Act) at a total income of Rs. 1,63,03,51,760/-. The said order was appealed against before the CIT(A), who vide order dated 04.03.2004 partly allowed the appeal. On further appeal before this Tribunal, this Tribunal vide order dated 16....

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....st. 7. Being aggrieved, the appellant is in appeal before this Tribunal in the present appeal. 8. The learned counsel for the assessee submitted that the appellant is entitled for interest u/s. 244A of the Act even on interest granted u/s. 244A of the Act. In support of this he placed reliance on the following decisions: - i) Union of India v. Tata Chemicals Ltd. [2014] 363 ITR 658 ii) Union Bank of India v. ACIT [2016] 52 ITR(T) 221 (Mum) iii) Tata Sons (P.) Ltd. v. DCIT [2024] 204 ITD 802 (Mum) 9. On the other hand, the CIT-DR submits that the order passed by the CIT(A) is in consonance with the law laid down by the Hon'ble Apex Court in the case of CIT v. Gujarat Fluoro Chemicals [2014] 358 ITR 291, therefore, no interferenc....