DY. COMMISSIONER OF INCOME TAX CIRCLE - 3(3)(1), MUMBAI, MUMBAI vs. SMALL INDUSTRIES DEVELOPMENT BANK OF INDIA, MUMBAI

ITA 2894/MUM/2023Status: DisposedITAT Mumbai10 October 2025AY 2015-16Bench: JUSTICE (RETD.) C V BHADANG (President), MS PADMAVATHY S (Accountant Member)1 pages
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What did the Tribunal hold?

The Tribunal dismissed the revenue's appeals regarding bad debt deductions, upholding the CIT(A)'s decision based on previous rulings. For the lease premium issue, the Tribunal remitted the matter back to the AO for reconsideration based on a declaration filed by the assessee.

What were the facts?

The assessee claimed deductions for bad debts and lease premium, while the revenue disputed these claims and also issues related to disallowance under Section 14A. The CIT(A) provided partial relief to the assessee on some issues and upheld disallowances on others.

What were the issues?

Whether the deduction for bad debts under Section 36(1)(vii) is permissible when a provision for doubtful debts exists, and whether lease premium paid is a revenue expenditure eligible for proportionate deduction.

Which sections of the Income-tax Act were involved?

Section 36(1)(vii),Section 36(1)(viia)(c),Section 14A,Section 36(1)(viii),Section 158A

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Cases cited in this judgment(8)Show list

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Heard together (7 matters)

I.T.A. No. 2943/Mum/2023
I.T.A. No. 2894/Mum/2023
I.T.A. No. 2893/Mum/2023
I.T.A. No. 3160/Mum/2023
I.T.A. No. 3173/Mum/2023
I.T.A. No. 2971/Mum/2023
I.T.A. No. 2970/Mum/2023

Read from the judgment's own cause title. This page is filed under one of them.

IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE JUSTICE (RETD.) C V BHADANG, PRESIDENT & MS PADMAVATHY S, AM I.T.A. No. 2894/Mum/2023 (Assessment Year: 2015-16) I.T.A. No. 3160/Mum/2023 (Assessment Year: 2017-18) Dy. Commissioner of Income Small Industries Development Bank Tax, Circle-3(3)(1), of India, Room No. 609, Aayakar Bhavan, SME Development Centre, M.K. Road, Mumbai- 400020. Vs. C-11, G Block, Bandra Kurla Complex, Bandra (East), Mumbai-400051 PAN: AABCS3480N Appellant) : Respondent) I.T.A. No. 2970/Mum/2023 (Assessment Year: 2018-19)

2 ITA 2943-2894-2893-3160-3173/M/ 2023 & 2971-2970/M/ 2023 Small Industries Development Bank of India Small Industries Development Dy. Commissioner of Income Tax, Bank of India, Circle-3(3)(1), SME Development Centre, Room No. 609, Aayakar Bhavan, C-11, G Block, Bandra Kurla Vs. M.K. Road, Mumbai- 400020. Complex, Bandra (East), Mumbai-400051 PAN: AABCS3480N Appellant) : Respondent) Revenue by : Shri Arun Kanti Dat

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