THE VIRUDHUNAGAR DIST CETNRAL CO- OPERATIVE BANK LIMITED,VIRUDHUNAGAR vs. DCIT,-DCAT, MADURAI-2,, VIRUDHUNAGAR
What did the Tribunal hold?
The Tribunal held that the deduction under Section 36(1)(viia) is limited to the actual provision made for bad and doubtful debts in the assessee's books, subject to the ceiling prescribed by the section. If the provision made is less than the prescribed limit, the deduction is restricted to the actual provision.
What were the facts?
The assessee, a co-operative bank, claimed deduction under Section 36(1)(viia) of the Income Tax Act for bad and doubtful debts. The Assessing Officer (AO) and CIT(A) restricted this deduction to the actual provision debited to the profit and loss account, rather than the maximum permissible limit.
What were the issues?
Whether the deduction under Section 36(1)(viia) for a co-operative bank is to be allowed based on the actual provision made for bad and doubtful debts or the maximum permissible limit irrespective of the provision made.
Which sections of the Income-tax Act were involved?
Section 36(1)(viia),Section 148,Section 143(3),Section 147,Section 250
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Cases cited in this judgment(4)Show listHide list
Detected automatically from the text. Citations are also linked where they appear in the judgment. The count shows how many other judgments on BharatTax rely on the same authority.
- State Bank of Patiala v. CIT62 citing272 ITR 54 · 2005 · HC
- DCIT v. ING Vysya Bank36 citing42 Taxmann.com 303 · 2014
- CIT v. Syndicate Bank28 citing422 ITR 460 · 2020 · HC
- Appellant on Southern Technologies v. JCIT4 citing228 ITR 440 · 2010 · SC
Income Tax Appellate Tribunal, `C BENCH, CHENNAI
Before: SHRI GEORGE GEORGE K & SHRI JAGADISH
PER GEORGE GEORGE K, VICE PRESIDENT:
These appeals at the instance of the assessee are directed against five orders of the CIT(A)/NFAC orders dated 24.07.2024 / 25.07.2025 passed u/s.250 of the Income Tax Act, 1961 (hereinafter called as “Act”). The relevant assessment years are 2009-10 to 2012-13 and 2014-15. 2. There is a delay of
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More judgments on Section 36(1)(viia)
- M/S Malwa Gramin Bank Now Known As Punjab… vs DCIT, SangrurITA 283/CHANDI/2019[2015-16]Status: Disposed29 Sept 2026AY 2015-16
- M/S the Malwa Gramin Bank, Sangrur vs ACIT, Circle, SangrurITA 1181/CHANDI/2018[2014-15]Status: Disposed29 Sept 2026AY 2014-15
- M/S the Malwa Gramin Bank, Sangrur vs Dy Commissioner of Income Tax, SangrurITA 156/CHANDI/2017[2011-12]Status: Disposed29 Sept 2026AY 2011-12
- Rajasthan Marudhara Gramin Bank, Jodhpur vs DCIT, Circle-1, JaipurITA 1248/JPR/2025[2018-19]Status: Disposed28 Sept 2026AY 2018-19
- State Bank of India, Mumbai vs ACIT-Circle- 2(2)(1), MumbaiITA 3429/MUM/2018[2013-14]Status: Disposed11 Sept 2026AY 2013-14
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