Held, affirming the decision of the High Court, the Court held that salary and perquisites paid by the assessee-bank to its employees are to be apportioned under section 21 of the Income-tax Act, 1961 and the provisions of section 40A(5) would be made applicable only in respect of that portion of the salary and perquisite as is considered under section 28 of the Act.(AY.1982-83)
CIT v. Bank of America (2024)469 ITR 406 (SC) Editorial: Decision of Bombay High Court in CIT v. Bank of America (Bom)(HC)(ITR No. 81 of 1994 dt. 22-7-2023, Followed, CITv. Citi Bank N.A. (No. 2 (2024) 469 ITR 398 (SC)
S. 28(i) : Business income-Accrual of income-Banks-Interest on doubtful loans-Determined in accordance with Central Board of Direct Taxes Circular. [S. 21, 40A(5), 119]
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