High Court of Karnataka · Judgments and reasoned final orders
Principal Commissioner of Income Tax & Anr. v. M/s Syndicate Bank (Now Canara Bank)
Income Tax Appeal No. 6 of 2025 ·
Inapplicability of Minimum Alternate Tax (MAT) under Section 115JB (prior to Finance Act, 2012 amendment) to banking companies governed by the Banking Regulation Act, 1949 for AY 2002-03, following CIT v. ING Vysya Bank Ltd. (2020) 422 ITR 116 (Kar).
1. FACTS OF THE CASE
The Revenue appealed under Section 260A against the ITAT Bengaluru Bench order holding that the provisions of Section 115JB (Minimum Alternate Tax) were not applicable to M/s Syndicate Bank for AY 2002-03.
2. DISCUSSION BY THE COURT
The Division Bench observed that the question whether Section 115JB applied to banking companies prior to the Finance Act, 2012 amendment (effective 01.04.2013) is squarely covered against the Revenue by the decision of the Karnataka High Court in CIT v. ING Vysya Bank Ltd. (2020) 422 ITR 116 (Kar) and subsequent orders in the assessee's own case, as banking companies prepared their accounts under the Banking Regulation Act, 1949 rather than Schedule VI of the Companies Act, 1956.
3. JUDICIAL DECISION
Answering the substantial questions of law in favour of the assessee and against the Revenue, the High Court dismissed the appeal.
4. OUTCOME
Assessee - Revenue appeal dismissed; Section 115JB held inapplicable to Syndicate Bank for AY 2002-03.
5. AKHB REVIEW POINT
For assessment years prior to AY 2013-14 (before the Finance Act, 2012 amendment to Section 115JB(2)), banking companies preparing accounts under the Banking Regulation Act, 1949 are outside the ambit of MAT under Section 115JB.
Source and verification
5-page official High Court of Karnataka judgment PDF (20260205_KAHC010003202025.pdf, 88,018 bytes).
Original PDF: 5 pages · SHA-256: 4842e6be92cb9a05e5e14378fe225aa67a41705bfe37b05c6919f50034756ab5
Supplied source-reviewed note retained; original bytes and identity validation checked in this release. Substantive re-review is not claimed for this record.
Applies Section 115JB of the Income-tax Act, 1961 as it stood in AY 2002-03 (prior to Finance Act, 2012 amendment effective 01.04.2013). Income-tax Act, 2025 equivalence is not verified.
Full 5-page primary judgment PDF text read and verified page-by-page. Follows CIT v. ING Vysya Bank Ltd. (2020) 422 ITR 116 (Kar) and coordinate bench ruling in Canara Bank.
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