2025 (8) TMI 1815

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....N'BLE MR. JUSTICE K. V. ARAVIND For the Appellants: (By Sri Thirumalesh M., Advocate). For the Respondent: (By Smt. Tanmayee Rajkumar, Advocate). ORAL JUDGMENT (PER: HON'BLE MR. JUSTICE K. V. ARAVIND) Heard Sri M. Thirumalesh, learned counsel appearing for the appellants-Revenue and Smt. Tanmayee Rajkumar, learned counsel appearing for the respondent-Assessee. 2. This app....

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....estments has appreciated, which is in violation of RBI Guidelines for classification and valuation of investments by banks dated 16-10-2000 and also contrary to CBDT Circular No.665 (F.No. 201/3/92-ITA-II dated 05-10-1993)? 2. Whether the ITAT is justified in ignoring that the assessee ought to have netted off the depreciation against the appreciation in other investments? 3. Whe....

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....impugned order, has followed its earlier order in the case of the assessee for the Assessment Year 2014-15 and has held the issues in favour of the assessee. It is further submitted that the substantial questions of law raised in the present appeal have already been answered by this Court in favour of the assessee in the case of Karnataka Bank Ltd. v. Assistant Commissioner of Income-tax, Circle 2....

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....ed order passed by the Tribunal and the judgment of this Court in the case of Karnataka Bank Ltd. (supra). The Tribunal, in the impugned order, has extracted the grounds raised by the Revenue. The issue canvassed by the learned Senior Standing Counsel regarding netting of appreciation was not raised for consideration before the Tribunal. An issue not raised before the Tribunal cannot form the subj....