SHRI RAJKOT DISTRICT CO-OPERATIVE BANK LTD.,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(2), RAJKOT , RAJKOT

ITA 196/RJT/2024Status: DisposedITAT Rajkot04 November 2025AY 2011-12Bench: DR. ARJUN LAL SAINI (Accountant Member), SHRI DINESH MOHAN SINHA (Judicial Member)1 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the write-back of provision for bad and doubtful debts is taxable as income. It also rejected the assessee's contention that a revisionary order under Section 263 was invalid due to non-confrontation regarding Explanation 2.

What were the facts?

The assessee, a co-operative bank, claimed a deduction for provision for bad and doubtful debts on standard assets. The Assessing Officer disallowed this provision and also added back an amount transferred from bad and doubtful debts provision to a general reserve as income.

What were the issues?

Whether a write-back of provision for bad and doubtful debts is taxable as income, and whether a revisionary order under Section 263 is valid without prior confrontation on specific explanations.

Which sections of the Income-tax Act were involved?

Section 36(1)(viia),Section 263,Section 144C(1)

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Cases cited in this judgment(9)Show list

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Income Tax Appellate Tribunal, RAJKOT BENCH, RAJKOT

Before: DR. ARJUN LAL SAINI & SHRI DINESH MOHAN SINHA

For Appellant: Shri D.M. Rindani, Ld. AR
For Respondent: Smt. Pallavi, Ld. CIT(DR)
Pronounced: 04/11/2025

Per, Dinesh Mohan Sinha, JM: Captioned appeal filed by the assessee, pertaining to Assessment Year (AY)-2018-19, is directed against the order passed by the Commissioner of Income Tax Office [(in short “Ld.CIT(A)”] vide order dated 29.12.2023, which in turn assessment order passed by Income Tax Department / Assessing Officer under section 144C(1) of the Income Tax Act, 1961 (in short “the Act”), vide order dated 30.03.2023

2.

Grounds of appeal raised by the asse

The order continues below.

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