DEPUTY COMMISSIONER OF INCOME TAX CIRCLE -IV, KAPURTHALA vs. M/S PUNJAB GRAMIN BANK, KAPURTHALA

ITA 731/ASR/2017Status: DisposedITAT Amritsar05 April 2019AY 2014-1518 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that the provision for bad and doubtful debts against standard assets is covered under Section 36(1)(viia) of the IT Act. Therefore, the addition made by the AO on this count was rightly deleted by the CIT(A).

What were the facts?

The assessee bank made interest payments to Punjab Technical University (PTU) and claimed it as an expenditure. The Assessing Officer disallowed this interest payment for non-deduction of TDS, citing Section 40(a)(ia). The bank also claimed a provision for bad and doubtful debts against standard assets, which the AO disallowed.

What were the issues?

Whether the interest paid to PTU was disallowable due to non-deduction of TDS, and whether provision for bad and doubtful debts against standard assets is allowable as a deduction.

Which sections of the Income-tax Act were involved?

Section 40(a)(ia),Section 36(1)(viia),Section 194A,Section 197,Section 36(1)(vii)

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Cases cited in this judgment(2)Show list

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Income Tax Appellate Tribunal, Camp Bench at Jalandhar

Before: Shri N.K. Saini & Shri Ravish Sood

For Appellant: Shri Ranjan Sehgal, A.R
For Respondent: Smt. Parvinder Kaur, C.I.T, D.R
Hearing: 16.01.2019Pronounced: 05.04.2019

PER RAVISH SOOD, JM The present cross appeals filed by the assessee and the revenue are directed against the order passed by the CIT (Appeals)-2,

P a g e | 2 ITA No. 784 & 731/Asr./2017 A.Y. 2014-15 Punjab Gramin Bank Vs. DCIT & DCIT Vs. Punjab Gramin Bank

Jalandhar, dated 27.09.2017, which in turn arises from the assessment order passed by the A.O under Sec. 143(3) of the Income Tax Act, 1961 (for short ‘IT Act’) for A.Y. 2014-15, dated 16.12.2016. The assessee assailing

The order continues below.

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