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2025 DAILYLAW 56842 (KAR)

THE COMMISSIONER OF INCOME TAX v. M/S CANARA BANK

RP/207/2023 · 2025-11-18

B M Shyam Prasad, G Basavaraja

Review Petitionbody2025

Judgment text

Extracted from the PDF above. The PDF is authoritative.

- 1 - HC-KAR NC: 2025:KHC:47472-DB RP No. 207 of 2023 IN THE HIGH COURT OF KARNATAKA AT BENGALURU DATED THIS THE 18TH DAY OF NOVEMBER, 2025 PRESENT THE HON'BLE MR. JUSTICE B M SHYAM PRASAD AND THE HON'BLE MR. JUSTICE G BASAVARAJA REVIEW PETITION NO. 207 OF 2023 BETWEEN: 1. THE COMMISSIONER OF INCOME TAX CIT(A) LTU, 7TH FLOOR, BMTC BUILDING, 80 FEET ROAD, KORAMANGALA, BENGALURU 560095 2. THE JOINT COMMISSIONER OF INCOME TAX LTU PRESENT ADDESS DCIT, CIRCLE 2(1)(10 2ND FLOOR, BMTC BUILDING, 80 FEET ROAD, ORAMANGALA, Digitally signed by LAKSHMINARAYAN N Location: HIGH COURT OF KARNATAKA - 2 - HC-KAR NC: 2025:KHC:47472-DB RP No. 207 of 2023 BENGALURU 560095 …PETITIONERS (BY SRI. Y.V. RAVIRAJ A/W SRI DILIP M., ADVOCATES) AND: 1. M/S CANARA BANK HEAD OFFICE 112, J C ROAD BENGALURU 560002 …RESPONDENT (BY MS. TANMAYEE RAJKUMAR, ADVOCATE) THIS REVIEW PETITION IS FILKED UNDER ORDER XLVII RULE 1 READ WITH SECTION 114 OF CPC, PRAYING TO REVIEW THE ORDER DATED 10.01.2023 PASSED BY THIS COURT ITA NO.300/2018; AND ETC. THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER: CORAM: HON'BLE MR. JUSTICE B M SHYAM PRASAD and HON'BLE MR. JUSTICE G BASAVARAJA - 3 - HC-KAR NC: 2025:KHC:47472-DB RP No. 207 of 2023 ORAL ORDER (PER: HON'BLE MR. JUSTICE B M SHYAM PRASAD) The Revenue seeks review of this Court's order dated 10.01.2023 in ITA No.300/2018. This Court has dismissed the Revenue's appeal holding that the questions proposed as substantial questions of law are covered against the Revenue in ITA No.268/2018. Sri Y.V. Raviraj, the learned Senior Standing Counsel along with Sri M. Dilip, the learned Counsel for the appellant, and Ms. Tanmayee Rajkumar, the learned Counsel for the respondent, are heard for final disposal. Sri Y.V. Raviraj, with regard to the Revenue's request to review this Court's Order dated 10.01.2023, submits that with the rectification Order dated 29.06.2018 in MP No.113/Bang/2018, the Income Tax Appellate Tribunal has rectified the order dated 24.10.2017 impugned in ITA No.300/2018 - 4 - HC-KAR NC: 2025:KHC:47472-DB RP No. 207 of 2023 substituting paragraph 13 in its order. It could be discerned from Sri Y.V. Raviraj's submission that the Tribunal has clarified the issue on allowing deduction under Section 36(1)(vii) of the Income Tax Act, 1961. With this clarification, this Court opines that there is no reason for interference for review and the petition stands dismissed accordingly and also the application for condonation of delay in filing this review petition is also dismissed. Sd/- (B M SHYAM PRASAD) JUDGE Sd/- (G BASAVARAJA) JUDGE lnn List No.: 1 Sl No.: 5