THE MODAS NAGARIK SAHAKARI BANK LTD.,ARVALLI vs. THE ACIT, CIRCLE-2(1)(1), AHMEDABAD

ITA 1573/AHD/2025Status: DisposedITAT Ahmedabad28 January 2026AY 2018-19Bench: Shri Sanjay Garg, Judicial Member And Annapurna Gupta (Accountant Member)4 pages
AI SummaryRemanded

What did the Tribunal hold?

For both grounds of appeal, the Tribunal remanded the matter to the Assessing Officer (AO). The AO was directed to verify the assessee's separate accounts/computation and the DR's contention regarding the expenses. For the bad debts provision, the AO was directed to verify the claim and allow it if the assessee is entitled under Section 36(1)(viia) of the Act.

What were the facts?

The assessee, a cooperative bank, appealed against the CIT(A)'s confirmation of two disallowances for AY 2018-19. The first was for expenses of Rs. 53,62,300, not debited to the P&L account but deducted from reserves. The second was an addition of Rs. 27,42,118 for provision for doubtful debts, which the assessee claimed was duly made and allowable under the Income Tax Act.

What were the issues?

Whether expenses not debited to the P&L account but adjusted against reserves are allowable deductions; Whether provision for doubtful debts is allowable under Section 36(1)(viia) when the assessee claims it was duly made in books of accounts.

Which sections of the Income-tax Act were involved?

Section 250,Section 36(1)(viia)

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Income Tax Appellate Tribunal, “ C ” BENCH, AHMEDABAD

Before: Shri Sanjay Garg & Annapurna Gupta

For Appellant: Shri Dhinal Shah, AR
Hearing: 21/01/2026Pronounced: 28/01/2026

Per Sanjay Garg, Judicial Member:

The present appeal has been preferred by the assessee against the order of the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as ‘CIT(A)’] dated 31/07/2025 passed u/s.250 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for the Assessment Year (AY) 2018-19. 2. The assessee, in this appeal, has taken

The order continues below.

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