The assessee is a subsidiary of PNB. The deduction has been claimed u/s 36(1)(viii) taking into account percentage of total interest received on Long Term housing loan has been upheld by the ITAT stating that the said methodology has been adopted by the assessee consistently and the same was accepted by the Revenue without any objection. The Revenue had not filed appeal challenging the deduction allowed in the preceding years. Following the judgment of the Supreme Court in Pr. CIT v. Maruti Suzuki India Ltd. (2019) 107 taxmann.com 375 / 265 Taxman 215 / 416 ITR 613, Revenue’s appeal dismissed. (AY. 2010-11)
PCIT v. PNB Housing Finance Ltd. (2023) 146 taxmann.com 445 / (2024) 461 ITR 476 (Delhi)(HC)
S. 36(1)(iii) : Interest on borrowed capital-Business of retail lending as well as Long Term finance for construction of homes-Deduction claimed on interest on Long Term housing loan, which has been recalculated by the AO based on total receipt of the business-Rule of consistency is followed-Order of Tribunal deleting the addition is affirmed.[S.260A]