DY.COMMISSIONER OF INCOME TAX, THRISSUR vs. THE CSB BANK LTD, THRISSUR

ITA 542/COCH/2025Status: DisposedITAT Cochin30 October 2025AY 2014-15Bench: SHRI INTURI RAMA RAO, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)1 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that if provisions for bad and doubtful debts are debited to the profit and loss account and simultaneously reduced from the asset side of the balance sheet, it amounts to an actual write-off. Consequently, such provisions do not attract the add-back provisions under Section 115JB(2) of the Income Tax Act.

What were the facts?

The Revenue appealed against the CIT(A)'s order which partly allowed the assessee's appeal against an assessment order. The core issue was the enhancement of book profits by Rs. 57.57 crores due to provisions made for bad and doubtful debts.

What were the issues?

Whether provisions for bad and doubtful debts, when adjusted against the asset side, should be added back to book profits for Minimum Alternate Tax (MAT) purposes under Section 115JB.

Which sections of the Income-tax Act were involved?

Section 115JB,Section 147,Section 144B,Section 250,Section 36(1)(vii)

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Cases cited in this judgment(11)Show list

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Income Tax Appellate Tribunal, “DB” BENCH, COCHIN

[ Per Rahul Chaudhary, Judicial Member:

1.

The present appeal preferred by the Revenue is directed against the order, dated 25/03/2025, passed by National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as ‘the NFAC’] under Section 250 of the Income Tax Act, 1961 [hereinafter referred to as ‘the Act’] whereby the Ld. CIT(A) had partly allowed the appeal against the Assessment Order, dated 16/03/2022, passed under Section 147 read with Section 144B of the Act for the Assessment Year 2014- 2015. 1. 1. The appeal preferred by the Revenue was delayed by 60 days. We have head both the sides on app

The order continues below.

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