TMI Blog2021 (9) TMI 555X X X X Extracts X X X X X X X X Extracts X X X X ..... Kumar Sukumara Kurup For the Appellant : Mrs.R.Hemalatha Senior Standing Counsel in both appeals For the Respondent : Mr.R.Vijayaraghavan for M/s.Subbaraya Aiyar Padmanabhan in both appeals COMMON JUDGMENT T.S. SIVAGNANAM, J. These Tax Case Appeals filed by the Revenue under Section 260-A of the Income Tax Act, 1961 ( the Act for brevity) are directed against the common order, dated 30.08.2011, passed by the Income Tax Appellate Tribunal, Chennai, A Bench, in I.T.A.Nos.780/Mds/2001 and 781/Mds/2001, for the Assessment Years 1990-91 and 1991-92 respectively. 2.The appeals were admitted on 02.02.2016 to decide the following substantial questions of law : 1.Whether on the facts and in the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tances of the case, the Income Tax Appellate Tribunal was right in deleting the additions made on interest on securities? 2.Is not the finding of the Tribunal bad by deleting the additions made on interest on securities especially when the assessee has credited interest on day to day basis in its books of accounts as per mercantile system of accounting being followed whereby the entire interest income had accrued during the year? 3.Whether the Tribunal was right in law in holding that the loss on revaluation of securities is to be allowed irrespective of the fact that the assessee had valued the investment at cost price in its book but however for the Income Tax purposes valuation was made as cost price or market price whichev ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... peals have been answered in favour of the assessee by the Hon'ble Division Bench of this Court in the case of Commissioner of Income Tax vs. City Union Bank Ltd. [(2007) 291 ITR 0144 (Mad)] and in the case of Commissioner of Income Tax vs. Karur Vysya Bank Ltd. [(2009) 77 CCH 0603 CHenHC and in The Commissioner of Income Tax, Trichy vs. The Lakshmi Vilas Bank Ltd., in T.C.A.No.207 of 2018 dated 04.11.2020 . 7.The first substantial question of law with regard to the additions made on the interest on securities was the first substantial question of law framed for consideration in the case of City Union Bank Ltd. and it was held in favour of the assessee in the following terms: 4.1. With regard to the first subst ..... X X X X Extracts X X X X X X X X Extracts X X X X
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