State Bank of India, RBO Udupi v. Income Tax Officer, TDS Ward, Mangalore

1. FACTS OF THE CASE

SBI’s Udupi Regional Business Office challenged the ITAT order dated 1 July 2024, limited to ITA 985/Bang/2024 for AY 2016-17. Tax and interest under sections 201(1) and 201(1A) arose from failure to deduct TDS on employees’ foreign-travel LTC reimbursements. SBI claimed section 10(5) exemption and consequently no section 192 deduction obligation. The High Court first condoned 63 days’ appeal delay.

Source: Paragraphs1–5; PDF pp.2–3

2. DISCUSSION BY THE COURT

The ITAT followed the bank’s case in ITA 317/Bang/2024. The High Court recorded that the appeal from that order, ITA 66/2025, had been dismissed separately that day following State Bank of India v. ACIT, (2023)1 SCC 162. The present issues were admittedly covered and the appeal had to meet the same result.

Source: Paragraphs6–7; PDF pp.3–4

3. JUDICIAL DECISION

No substantial question of law arose; the bank’s appeal was dismissed after condonation of delay.

Source: Paragraphs1,8; PDF pp.2,4

4. OUTCOME

The bank obtained consideration despite delay but no relief on TDS liability. The challenged tax and interest for AY 2016-17 remained undisturbed.

Source: Paragraphs3–8; PDF pp.3–4

5. Expert Comments

AKHB editorial analysis, distinct from the Court’s findings.

Exemption and withholding were linked

SBI’s argument depended on treating the reimbursement as exempt under section 10(5). The recorded overseas travel defeated that position through the governing precedent. For a comparable payroll dispute, the actual itinerary and reimbursement record matter; an employer’s LTC label alone cannot establish the exemption.

Source: PDF p.3 · PDF p.4

The companion case supplies the fuller reasoning

This judgment resolves a covered issue by reference to ITA 66/2025 and the Supreme Court ruling. It does not independently analyse every possible travel arrangement, valuation question or withholding defence. Detailed reliance requires the incorporated decisions as well as this bank-specific result.

Source: PDF p.3 · PDF p.4

Keep the appeal scope distinct from the common ITAT order

The ITAT common order concerned ITA 983,984 and 985/Bang/2024, but this High Court appeal concerns 985 alone. The 63-day delay was condoned; that procedural success did not affect the adverse merits result. Neither the other appeals nor their liabilities should be silently merged into this record.

Source: PDF p.2 · PDF p.4