Catholic Syrian Bank Ltd. v. CIT

343 ITR 270Supreme Court of India2012#235 most cited

What is Catholic Syrian Bank Ltd. v. CIT authority for?

For a bad debt deduction under Section 36(1)(vii), the debt must be actually written off as irrecoverable in the assessee's accounts, distinct from merely making a provision for bad and doubtful debts. The assessee bears the onus to satisfy the conditions under both Section 36(1)(vii) and Section 36(2) of the Income-tax Act.

326

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2012 to 2026.

Also referred to as

Catholic Syrian Bank Ltd. v. CIT · Section 36(1)(vii) · Section 36(1)(viia) · bad debt deduction · actual write-off · provision for bad and doubtful debts · irrecoverable debt · Section 36(2) · banking companies · TRF Ltd distinguished · Southern Technologies Ltd followed

Also reported as

206 Taxmann 1823 SCC 784

Sections most often in play

Section 36(1)(vii)Section 36(1)(viia)Section 14ASection 143(3)Section 37(1)Section 36(1)(viii)Section 115JBSection 250
Read the full judgment

Issues it is cited on

section 36(2)(v)section 41(4)section 36(1)(viia)section 36(2)section 36(1)(v)section 36(1)(viii)section 46section 36(1)(vii)section 35dsection 10(34)eligible businessinterest on securities

Judgments citing Catholic Syrian Bank Ltd. v. CIT

Dy. Commissioner of Income Tax Circle - 3(3)(1), Mumbai vs. Small Industries Development Bank of India, Mumbai

ITA 2943/MUM/2023[2014-15]Status: DisposedITAT Mumbai10 Oct 2025AY 2014-15

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Respondent: Shri Arun Kanti Datta, CIT-DR
Section 115JSection 14ASection 250Section 36(1)Section 36(1)(vii)Section 36(1)(viia)

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE JUSTICE (RETD.) C V BHADANG, PRESIDENT & MS PADMAVATHY S, AM I.T.A. No. 2943/Mum/2023 (Assessment Year: 2014-15) I.T.A. No. 2894/Mum/2023 (Assessment Year: 2015-16) I.T.A. No. 2893/Mum/2023 (Assessment Year: 2016-17) I.T.A. No. 3160/Mum/2023 (Assessment Year: 2017-18) I.T.A. No. 3173/Mum/2023 (Assessment Year: 2018-19) Dy. Commissioner of Income Small Industries Development Bank Tax, Circle-3(3)(1), of India, Room No. 609, Aayakar Bhavan, SME Development Centre, M.K. Road, Mumbai- 400020. Vs. C-11, G Block, Bandra Kurla Complex, Bandra (East), Mu…

Dy. Commissioner of Income Tax Circle - 3(3)(1), Mumbai vs. Small Industries Development Bank of India, Mumbai

ITA 2894/MUM/2023[2015-16]Status: DisposedITAT Mumbai10 Oct 2025AY 2015-16

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Respondent: Shri Arun Kanti Datta, CIT-DR
Section 115JSection 14ASection 250Section 36(1)Section 36(1)(vii)Section 36(1)(viia)

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE JUSTICE (RETD.) C V BHADANG, PRESIDENT & MS PADMAVATHY S, AM I.T.A. No. 2943/Mum/2023 (Assessment Year: 2014-15) I.T.A. No. 2894/Mum/2023 (Assessment Year: 2015-16) I.T.A. No. 2893/Mum/2023 (Assessment Year: 2016-17) I.T.A. No. 3160/Mum/2023 (Assessment Year: 2017-18) I.T.A. No. 3173/Mum/2023 (Assessment Year: 2018-19) Dy. Commissioner of Income Small Industries Development Bank Tax, Circle-3(3)(1), of India, Room No. 609, Aayakar Bhavan, SME Development Centre, M.K. Road, Mumbai- 400020. Vs. C-11, G Block, Bandra Kurla Complex, Bandra (East), Mu…

Dy. Commissioner of Income Tax Circle - 3(3)(1), Mumbai vs. Small Industries Development Bank of India, Mumbai

ITA 2893/MUM/2023[2016-17]Status: DisposedITAT Mumbai10 Oct 2025AY 2016-17

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri Arun Kanti Datta, CIT-DR
Section 115JSection 14ASection 250Section 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

…IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE JUSTICE (RETD.) C V BHADANG, PRESIDENT & MS PADMAVATHY S, AM I.T.A. No. 2943/Mum/2023 (Assessment Year: 2014-15) I.T.A. No. 2894/Mum/2023 (Assessment Year: 2015-16) I.T.A. No. 2893/Mum/2023 (Assessment Year: 2016-17) I.T.A. No. 3160/Mum/2023 (Assessment Year: 2017-18) I.T.A. No. 3173/Mum/2023 (Assessment Year: 2018-19) | Dy. Commissioner of Income Tax, Circle-3(3)(1), Room No. 609, Aayakar Bhavan, M.K. Road, Mumbai- 400020. | Small Industries Development Bank of India, SME Development Centre, Vs. C-11, G Block, Bandra Kurla Complex, Bandra (East…

DCIT, Cen Cir 2(2), Chennai vs. Jayapriya Company, Chennai

In the result, both the appeals of the Revenue are dismissed and

ITA 1252/CHNY/2025[2022-23]Status: DisposedITAT Chennai12 Sept 2025AY 2022-23

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.G. Baskar, AdvocateFor Respondent: Mrs. Yamuna, CIT
Section 132Section 139Section 147Section 148Section 250

…HC) the Hon'ble Delhi High Court held that a bad debt written off in the books of accounts need not be proven as irrecoverable to claim a deduction under Section 36(1)(vii) of the Income Tax Act. 6.3.19 In the case of Catholic Syrian Bank Ltd. v. CIT (2012) 343 ITR 270 (SC) the Hon'ble Apex Court held that the benefit of deduction under Section 36(1)(vii) for bad debts written off is available to all debts irrespective of their classification as rural or urban advances. 6.3.20 In light of the above discussions, judicial precedents, and the CBDT Circular/Instructions, the undersigned is of the considered view t…

DCIT, CC2(2), Chennai vs. Jayapriya Company, Chennai

In the result, both the appeals of the Revenue are dismissed and

ITA 1251/CHNY/2025[2021-22]Status: DisposedITAT Chennai12 Sept 2025AY 2021-22

Bench: Shri Aby T. Varkey & Shri Amitabh Shukla

For Appellant: Mr.G. Baskar, AdvocateFor Respondent: Mrs. Yamuna, CIT
Section 132Section 139Section 147Section 148Section 250

…HC) the Hon'ble Delhi High Court held that a bad debt written off in the books of accounts need not be proven as irrecoverable to claim a deduction under Section 36(1)(vii) of the Income Tax Act. 6.3.19 In the case of Catholic Syrian Bank Ltd. v. CIT (2012) 343 ITR 270 (SC) the Hon'ble Apex Court held that the benefit of deduction under Section 36(1)(vii) for bad debts written off is available to all debts irrespective of their classification as rural or urban advances. 6.3.20 In light of the above discussions, judicial precedents, and the CBDT Circular/Instructions, the undersigned is of the considered view t…

Central Bank of India, Mumbai vs. CIT(A)-3, Mumbai

In the result, the appeal by the Revenue for the

ITA 5346/MUM/2018[2013-14]Status: DisposedITAT Mumbai22 Aug 2025AY 2013-14

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri R.A. Dhyani, CIT-DR
Section 10Section 115JSection 14ASection 250Section 37(1)

…nces amounting to INR 676,66,66,143 as a deduction under Section 36(1)(vii) of the Act in its return of income. In this regard, the assessee placed reliance upon the decision of the Hon'ble Supreme Court in Catholic Syrian Bank Ltd v/s CIT, reported in [2012] 343 ITR 270 (SC). The AO, vide order passed under section 143(3) of the Act, disagreed with the submissions of the assessee and held that there are no bifurcations of provision for rural and non-rural doubtful debts conceived by the legislature separately and distinct from each other. The AO further held that the assessee has not made any provisions on the l…

Jt. CIT (OSD) -2(1)(2), Mumbai vs. Central Bank of India, Mumbai

In the result, the appeal by the assessee for the

ITA 3674/MUM/2018[2013-14]Status: DisposedITAT Mumbai22 Aug 2025AY 2013-14

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri R.A. Dhyani, CIT-DR
Section 10Section 115JSection 14ASection 250Section 37(1)

…nces amounting to INR 676,66,66,143 as a deduction under section 36(1)(vii) of the Act in its return of income. In this regard, the assessee placed reliance upon the decision of the Hon'ble Supreme Court in Catholic Syrian Bank Ltd v/s CIT, reported in [2012] 343 ITR 270 (SC). The AO, vide order passed under section 143(3) of the Act, disagreed with the submissions of the assessee and held that there are no bifurcations of provision for rural and non-rural doubtful debts conceived by the legislature separately and distinct from each other. The AO further held that the assessee has not made any provisions on the l…

DCIT 2(1)(1), Mumbai vs. Central Bank of India, Mumbai

In the result, the appeal by the assessee for the

ITA 1223/MUM/2018[2015-16]Status: DisposedITAT Mumbai22 Aug 2025AY 2015-16

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri R.A. Dhyani, CIT-DR
Section 10Section 115JSection 14ASection 250Section 37(1)

…nces amounting to INR 676,66,66,143 as a deduction under section 36(1)(vii) of the Act in its return of income. In this regard, the assessee placed reliance upon the decision of the Hon'ble Supreme Court in Catholic Syrian Bank Ltd v/s CIT, reported in [2012] 343 ITR 270 (SC). The AO, vide order passed under section 143(3) of the Act, disagreed with the submissions of the assessee and held that there are no bifurcations of provision for rural and non-rural doubtful debts conceived by the legislature separately and distinct from each other. The AO further held that the assessee has not made any provisions on the l…

Central Bank of India, Mumbai vs. ACIT - 2(1)(2), Mumbai

In the result, the appeal by the assessee for the

ITA 1078/MUM/2018[2015-16]Status: DisposedITAT Mumbai22 Aug 2025AY 2015-16

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhail

For Appellant: Shri Nitesh JoshiFor Respondent: Shri R.A. Dhyani, CIT-DR
Section 10Section 115JSection 14ASection 250Section 37(1)

…nces amounting to INR 676,66,66,143 as a deduction under section 36(1)(vii) of the Act in its return of income. In this regard, the assessee placed reliance upon the decision of the Hon'ble Supreme Court in Catholic Syrian Bank Ltd v/s CIT, reported in [2012] 343 ITR 270 (SC). The AO, vide order passed under section 143(3) of the Act, disagreed with the submissions of the assessee and held that there are no bifurcations of provision for rural and non-rural doubtful debts conceived by the legislature separately and distinct from each other. The AO further held that the assessee has not made any provisions on the l…

Gaytri Devi Sharma, Chomu vs. ITO Ward 7(3), Jaipur

In the result, the appeal of the assessee is allowed

ITA 512/JPR/2025[2017-18]Status: DisposedITAT Jaipur20 Aug 2025AY 2017-18

Bench: Him.

For Appellant: Sh. C. L. Yadav, CAFor Respondent: Sh. Gautam Singh Choudhary, JCIT
Section 133(6)Section 139Section 142(1)Section 144Section 250Section 44ASection 69A

…issued by the CBDT are binding under section 119 of the Act on all officers and persons employed in the execution of the Act. Nature of a CBDT circular can be summarised in the words of hon’ble Supreme Court in the case of Catholic Syrian Bank Vs. CIT (2012) 343 ITR 270 (SC): “18. Now, we shall proceed to examine the effect of the circulars which are in force and are issued by the Central Board of Direct Taxes (for short, `the Board’) in exercise of the power vested in it under Section 119 of the Act. Circulars can be issued by the Board to explain or tone down the rigors of law and to ensure fair enforcement of…

ACIT (Ltu)-1, Mumbai vs. Union Bank of India, Mumbai

In the result, appeal of the assessee is allowed

ITA 882/MUM/2020[2015-16]Status: DisposedITAT Mumbai11 Aug 2025AY 2015-16

Bench: Shri Saktijit Dey, Hon'Ble & Shri Narendra Kumar Billaiya, Hon'Ble

For Appellant: Shri C Naresh, A/RFor Respondent: Shri Vivek Perampurna, CIT D/R
Section 115JSection 36(1)(vii)Section 36(1)(viia)

…anches are also required to be first debited to PBDD a/c and the excess amount alone can be allowed as deduction u/s 36(1)(vii) of the Act. According to revenue, the decision rendered by Hon'ble Supreme Court in the case of Catholic Syrian Bank Ltd. vs. DCIT (343 ITR 270) . In the above said case, the Hon'ble Supreme Court has expressed the view that the provisions of sec. 36(1)(vii) and 36(1)(viia) allow separate deduction and they are independent provisions. The Supreme Court further held that the clause (viia)(a) applies only to rural advances. But the sec. bad debts relating to non-rural advances need not be…

Income Tax Officer, Surat vs. The Sutex Co.Operative Bank Limited, Surat

In the result, the appeal of the revenue is dismissed

ITA 780/SRT/2024[2016-17]Status: DisposedITAT Surat05 Jun 2025AY 2016-17

Bench: Shri Sanjay Garg & Shri Bijayananda Prusethआयकर अपील सं./Ita No.780/Srt/2024 Assessment Year: (2016-17) (Hybrid Hearing) The Ito, Vs. The Sutex Co-Operative Bank Ltd., Ward – 1(1)(1), 2Nd Floor, Bank Block, Surat Textile Surat Market, Ring Road, Surat - 395002 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaaat2953Q (अपीलाथ" / Appellant) (""थ" / Respondent) Appellant By Shri Mukesh Jain, Sr. Dr Respondent By Shri Sapnesh Sheth, Ca Date Of Hearing 09/04/2025 Date Of Pronouncement 05/06/2025

Section 250Section 36(1)(via)Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

…l before the CIT(A). The CIT(A) has reproduced the submission of the appellant, which is at pages 3 to 10 of the appellate order. Before the CIT(A), the appellant relied on the decision of Hon’ble Supreme Court in case of Catholic Syrian Bank Limited vs. CIT, 343 ITR 270 (SC) and submitted that provisions of section 36(1)(vii) and 36(1)(viia) are distinct and independent of each other. The CIT(A) held that the appellant being co-operative bank, is duly entitled for deduction u/s 36(1)(viia) of the Act on account of provisions for bad and doubtful debts. He also referred to the decision of ITAT, Cochin in case of…

ACIT, Central Circle-2, Jaipur vs. Unimax Buildestate Pvt Ltd, Jaipur

In the result, the appeal of the revenue as well as cross objection of the

ITA 103/JPR/2024[2014-15]Status: DisposedITAT Jaipur08 May 2025AY 2014-15
For Appellant: Shri Deepak Sharma, AdvFor Respondent: Mrs. Swapnil Parihar, JCIT-DR
Section 143(2)Section 250

…आयकर अपीलीय अधिकरण, जयपुर न्यायपीठ, जयपुर IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”B” JAIPUR डॉ. एस.सीतालक्ष्मी, न्यायिक सदस्य एवं श्री राठोड कमलेश जयन्तभाई, लेखा सदस्य के समक्ष BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, AM आयकर अपील सं. / ITA. No. 103/JPR/2024 निर्धारण वर्ष / Assessment Years : 2014-15 ACIT, Central Circle-2, Jaipur. बनाम Vs. Unimax Buildestate Pvt. Ltd., A-47, Rathi Nagar, Nr. Rani Sati Nagar, Gopalpura Bye Pass, Ajmer Road, Jaipur. स्थायीलेखा सं./ जीआईआर सं./PAN/GIR No.: AABCU3476A अपीलार्थी / Appellant प्रत्यर्थी / Respondent C.O. No. 2/JPR/2024 (Arising o…

Dy. Commissioner of Income Tax, Circle-1(1), Hyderabad vs. Union Bank of India, Hyderabad

In the result, the appeal of revenue is partly allowed for statistical

ITA 316/HYD/2019[2015-16]Status: DisposedITAT Hyderabad21 Apr 2025AY 2015-16
For Appellant: Shri S. Ananthan, C.A. &For Respondent: Ms. M Narmada, CIT-DR
Section 143(3)Section 14ASection 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)Section 36(1)(vila)

…er contra, the Ld. DR submitted that, the ITAT in assessee's own case for A.Ys.2013-14 and 2014-15 (supra) has decided the issue in favour of the assessee relying on the decision of Hon'ble Supreme Court in the case of Catholic Syrian Bank Ltd. Vs. CIT (2012) 343 ITR 270 (SC). The Ld. DR further submitted that, after the order of Catholic Syrian Bank Ltd. Vs. CIT (supra), an amendment has been brought into the Act by insertion of Explanation 2 in section 36(1)(vii) of the Act w.e.f. 01.04.2014. Earlier, the Hon'ble Supreme Court in the case of Catholic Syrian Bank Ltd. Vs. CIT (supra) had held that, the provision…

Union Bank of India (Erstwhile-Andhra Bank), Mumbai vs. Dy. Commissioner of Income Tax, Circle-1(1), Hyderabad

In the result, the appeal of revenue is partly allowed for statistical purposes

ITA 193/HYD/2019[2015-16]Status: DisposedITAT Hyderabad21 Apr 2025AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri S. Ananthan, C.A. &For Respondent: Ms. M Narmada, CIT-DR
Section 143(3)Section 14ASection 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)Section 36(1)(vila)

…r contra, the Ld. DR submitted that, the ITAT in assessee's own case for A.Ys. 2013-14 and 2014-15 (supra) has decided the issue in favour of the assessee relying on the decision of Hon'ble Supreme Court in the case of Catholic Syrian Bank Ltd. Vs. CIT (2012) 343 ITR 270 (SC). The Ld. DR further submitted that, after the order of Catholic Syrian Bank Ltd. Vs. CIT (supra), an amendment has been brought into the Act by insertion of Explanation 2 in section 36(1)(vii) of the Act w.e.f. 01.04.2014. Earlier, the Hon'ble Supreme Court in the case of Catholic Syrian Bank Ltd. Vs. CIT (supra) had held that, the provision…

Abhyudaya Coop Bank Ltd, Mumbai vs. CIT (Appeals)-1, Mumbai

In the result, the appeal filed by the assessee stands allowed

ITA 882/MUM/2024[2018-19]Status: DisposedITAT Mumbai25 Mar 2025AY 2018-19

Bench: Smt. Beena Pillai () & Shri Omkareshwar Chidara ()

Section 143(2)Section 14ASection 263Section 36(1)(vii)

…submitted that the scope and limitations of Proviso to section 36(1)(vii) has been explained by the CBDT in its circulars. 3.2 The Ld.AR placed reliance on the decision of Hon’ble Supreme Court in case of Catholic Syrian Bank Ltd. Vs. CIT reported in (2012) 343 ITR 270. Hon'ble Supreme Court considered the CBDT circulars and explained the scope and limitations of Proviso to section 36(1)(vii) as under: "The provisions of sections 36(1)(vii) and (vila) of the Income-tax Act, 1961, are distinct and independent items of deduction and operate in their respective fields. Bad debts written off, other than those for…

Income Tax Officer, Ward-1, Nanded vs. Latur District Central Co Op Bank Ltd, Latur

In the result, the appeal of the Revenue is dismissed

ITA 1222/PUN/2024[2018-19]Status: DisposedITAT Pune28 Jan 2025AY 2018-19
For Appellant: Department byFor Respondent: Date of hearing
Section 143(2)Section 143(3)Section 36(1)(viia)

…ful debts reserves u/s 36(1)(viia) of the Act amounting to Rs.6,10,00,000/- are capital in nature. Relying on the decision(s) of Hon'ble Supreme Court in the case of Southern Technology Vs. JCIT 320 ITR 577 (SC) and in the case of Catholic Syrian Bank Vs. CIT 343 ITR 270 (SC) and the Hon'ble Madras High Court in the case of T.N. Power Investment Corporation Ltd. Vs. JCIT 280 ITR 491 (Mad.) and observing that the NPA is not same as bad and doubtful debts and mere provision for NPA is not allowable deduction u/s 36(1)(viia) of the Act, the Ld. AO disallowed the claim of the assessee u/s 36(1)(viia) of the Act total…

Union Bank of India, Hyderabad vs. Dy. Commissioner of Income Tax, Circle-1(1), Hyderabad

In the result, appeal filed by the assessee in ITA

ITA 365/HYD/2018[2014-15]Status: DisposedITAT Hyderabad24 Jan 2025AY 2014-15

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.350 & 351/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Dy. C. I. T. Vs. Andhra Bank Circle-1(1) Hyderabad Hyderabad [Pan : Aabca7375C] (Appellant) (Respondent) आ.अपी.सं /Ita No.364 & 365/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Union Bank Of India Vs. Dy. C. I. T. (Erstwhile Andhra Bank) Circle-1(1) Mumbai Hyderabad [Pan : Aaacu0564G (Aabca7375C)] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.Ananthan & Smt.Lalitha Rameswaran, Ar रधजस् व द्वधरध/Revenue By: Shri K.Meghnath Chowhan, Cit-Dr सुिवधई की तधरीख/Date Of 05/11/2024 Hearing: घोर्णध की तधरीख/Date Of 24/01/2025 Pronouncement: आदेश/Order Per Manjunatha G., A.M

For Appellant: Shri S.Ananthan &For Respondent: Shri K.Meghnath Chowhan
Section 143(3)Section 36(1)Section 36(1)(viii)

…e that the assessee has claimed bad debts written off in respect of non-rural debts written off at Rs.329,62,82,921/-. It was submitted that amount was claimed in view of the Hon'ble Supreme Court decision in the case of Catholic Syrian Bank Ltd vs CIT (2012) 343 ITR 270 (SC). The Assessing Officer did not accept the explanation of the assessee and according to the Assessing Officer, in the same judgment it was held that the claim of bad debts made u/s 36(1)(vii) should be limited to claim made u/s 36(1)(viia) and the overall claim of the assessee shall be subject to provisions of section 36(2)(v) of the Act. Sin…

Union Bank of India (Erstwhile- Andhra Bank), Mumbai vs. Dy. Commissioner of Income Tax, Circle-1(1), Hyderabad

In the result, appeal filed by the assessee in ITA

ITA 364/HYD/2018[2013-14]Status: DisposedITAT Hyderabad24 Jan 2025AY 2013-14

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.350 & 351/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Dy. C. I. T. Vs. Andhra Bank Circle-1(1) Hyderabad Hyderabad [Pan : Aabca7375C] (Appellant) (Respondent) आ.अपी.सं /Ita No.364 & 365/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Union Bank Of India Vs. Dy. C. I. T. (Erstwhile Andhra Bank) Circle-1(1) Mumbai Hyderabad [Pan : Aaacu0564G (Aabca7375C)] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.Ananthan & Smt.Lalitha Rameswaran, Ar रधजस् व द्वधरध/Revenue By: Shri K.Meghnath Chowhan, Cit-Dr सुिवधई की तधरीख/Date Of 05/11/2024 Hearing: घोर्णध की तधरीख/Date Of 24/01/2025 Pronouncement: आदेश/Order Per Manjunatha G., A.M

For Appellant: Shri S.Ananthan &For Respondent: Shri K.Meghnath Chowhan
Section 143(3)Section 36(1)Section 36(1)(viii)

…e that the assessee has claimed bad debts written off in respect of non-rural debts written off at Rs.329,62,82,921/-. It was submitted that amount was claimed in view of the Hon'ble Supreme Court decision in the case of Catholic Syrian Bank Ltd vs CIT (2012) 343 ITR 270 (SC). The Assessing Officer did not accept the explanation of the assessee and according to the Assessing Officer, in the same judgment it was held that the claim of bad debts made u/s 36(1)(vii) should be limited to claim made u/s 36(1)(viia) and the overall claim of the assessee shall be subject to provisions of section 36(2)(v) of the Act. Sin…

Dy. Commissioner of Income Tax, Circle-1(1), Hyderabad vs. Andhra Bank, Hyderabad

In the result, appeal filed by the assessee in ITA

ITA 351/HYD/2018[2014-15]Status: DisposedITAT Hyderabad24 Jan 2025AY 2014-15

Bench: Shri Manjunatha, G. & Shri K. Narasimha Charyआ.अपी.सं /Ita No.350 & 351/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Dy. C. I. T. Vs. Andhra Bank Circle-1(1) Hyderabad Hyderabad [Pan : Aabca7375C] (Appellant) (Respondent) आ.अपी.सं /Ita No.364 & 365/Hyd/2018 (निर्धारण वर्ा/Assessment Year: 2013-14 & 2014-15) Union Bank Of India Vs. Dy. C. I. T. (Erstwhile Andhra Bank) Circle-1(1) Mumbai Hyderabad [Pan : Aaacu0564G (Aabca7375C)] (Appellant) (Respondent) निर्धाररती द्वधरध/Assessee By: Shri S.Ananthan & Smt.Lalitha Rameswaran, Ar रधजस् व द्वधरध/Revenue By: Shri K.Meghnath Chowhan, Cit-Dr सुिवधई की तधरीख/Date Of 05/11/2024 Hearing: घोर्णध की तधरीख/Date Of 24/01/2025 Pronouncement: आदेश/Order Per Manjunatha G., A.M

For Appellant: Shri S.Ananthan &For Respondent: Shri K.Meghnath Chowhan
Section 143(3)Section 36(1)Section 36(1)(viii)

…e that the assessee has claimed bad debts written off in respect of non-rural debts written off at Rs.329,62,82,921/-. It was submitted that amount was claimed in view of the Hon'ble Supreme Court decision in the case of Catholic Syrian Bank Ltd vs CIT (2012) 343 ITR 270 (SC). The Assessing Officer did not accept the explanation of the assessee and according to the Assessing Officer, in the same judgment it was held that the claim of bad debts made u/s 36(1)(vii) should be limited to claim made u/s 36(1)(viia) and the overall claim of the assessee shall be subject to provisions of section 36(2)(v) of the Act. Sin…