Power Finance Corpn. Ltd. v. Joint Commissioner of Income-tax, Special Range-22

10 SOT 190Income Tax Appellate Tribunal2006#16442 most cited
5

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2023 to 2025.

Sections most often in play

Section 1961Section 143(3)Section 143(3) of the Income-tax ActSection 144 of the Income-tax ActSection 144B of the Income-tax ActSection 147 of the Income-tax ActSection 148 of the Income-tax ActSection 250 of the Income-tax Act

Issues it is cited on

section 36(1)(viia)section 254(1)gross total incomesection 36(1)section 254section 36section 80psection 37(1)section 37section 80appeal before the tribunalsection 25

Judgments citing Power Finance Corpn. Ltd. v. Joint Commissioner of Income-tax, Special Range-22

GS MAHANAGAR CO-OPERATIVE BANK LIMITED ,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX-CIRCLE -1(3)(2), MUMBAI

In the result, appeal of the assessee is allowed

ITA 1867/MUM/2025[2007-08]Status: DisposedITAT Mumbai04 Nov 2025AY 2007-08

Bench: BEFOREHON'BLE SHRI SAKTIJIT DEY (Vice President), MS PADMAVATHY S (Accountant Member)

For Appellant: Shri Dinesh Kukreja Adv. &For Respondent: Shri. Swapnil Choudhary Sr. AR
Section 143(3)Section 250Section 36(1)(viia)

…on 31.03.2008 is Rs. 73,39,100/-, 5.8 Further, in its submission, the assessee also relied upon the judicial pronouncements of (i) Rural Electrification Corporation Ltd [2009] 180 Taxman 55 (AAR New Delhi) and (ii) Power Finance Corporation Ltd V. JCIT [2006] 10 SOT 190 (Delhi Trib). However, on perusal of the above judgments, it is seen that the fact of the above cases are distinguishable with the facts of the case of the assessee. 5.9 In view of above discussion and discrepancies found in the submission by the assessee and the fact that the assessee has not made any provision of bad 4 GS Mahanagar Co-operative…

AMRELI JILLA MADHYASTH SAHAKARI BANK LTD.,AMRELI vs. THE DCIT-ACIT-2(1), RAJKOT, RAJKOT

In the result, the appeal of the assessee is allowed

ITA 548/RJT/2024[2014-15]Status: DisposedITAT Rajkot01 Jul 2025AY 2014-15

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं/.Ita No.548/Rjt/2024 "नधा"रणवष"/ Assessment Year: 2014-15 Amreli Jilla Madhyasth Sahakari The Dcit/Acit-2(1) बनाम Bank Ltd. Rajkot. Bhojalram Bhavan Vs. Rajmahel Road Amreli 365 601. Pan : Aaata 2737 J (अपीलाथ"/Appellant) : (""यथ"/Respondent) "नधा"रती क" ओर से/Assessee By : Shri D.M.Rindani, Ld.Ar राज"व क" ओर से/Revenue By : Shri Abhimanyu Singh Yadav, Sr-Dr

For Appellant: Shri D.M.Rindani, ld.ARFor Respondent: Shri Abhimanyu Singh Yadav, Sr-DR
Section 143(3)Section 144Section 147Section 148Section 250Section 36Section 36(1)(viia)

…serve-Held, yex - Whether mere debit in appropriation account would not, by self, disentitle assessee from claiming deduction under section 36(1) (viña) (c)-Held. yes iii. Power Finance Corpn. Ltd. V. Joint Commissioner of Income-tax, Special Range-22 [2006] 10 SOT 190 (DELHI) Section 36(1) (vita) of the Income-tax Act, 1961-Bad debts - Assessment year 1996-97 - Whether there is any pre-condition that amount claimed under clause (viia) of section 36(1) can be allowed under same if it is debited above line in profit and loss account Held, no Assessee claimed deduction under section 36(1)(c) Assessing Officer deni…

DEPUTY COMMISSIONER OF INCOME TAX, CIR-2(1)(1), BARODA vs. THE BHARUCH DIS CENT CO-OP BANK LTD., BHARUCH

ITA 298/SRT/2022[2017-18]Status: DisposedITAT Surat09 Jan 2023AY 2017-18

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 254(1)Section 36(1)(viia)

…debts is nothing but providing for bad and doubtful debts from the profit and loss accounts. The assessee also relied on the decision of Rural Electrification Corporation Limited (2009) 312 ITR 122 (AAR) and Delhi Tribunal in Power Finance Corporation (2006) 10 SOT 190 (Delhi). The assessee also stated that no such disallowance was made in AY 2007- 08 and 2008-09 in the assessment order passed under section 143(3). On DCIT Vs Bharuch Dist. Cent. Co-Op Bank ltd. the basis of afforesaid submission, the assessee claimed that they are eligible for deduction of 10% both as co-operative bank and also as non- schedule…

DEPUTY COMMISSIONER OF INCOME TAX, CIR-2(1)(1), BARODA vs. THE BHARUCH DIS CENT CO-OP BANK LTD., BHARUCH

ITA 297/SRT/2022[2016-17]Status: DisposedITAT Surat09 Jan 2023AY 2016-17

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 254(1)Section 36(1)(viia)

…debts is nothing but providing for bad and doubtful debts from the profit and loss accounts. The assessee also relied on the decision of Rural Electrification Corporation Limited (2009) 312 ITR 122 (AAR) and Delhi Tribunal in Power Finance Corporation (2006) 10 SOT 190 (Delhi). The assessee also stated that no such disallowance was made in AY 2007- 08 and 2008-09 in the assessment order passed under section 143(3). On DCIT Vs Bharuch Dist. Cent. Co-Op Bank ltd. the basis of afforesaid submission, the assessee claimed that they are eligible for deduction of 10% both as co-operative bank and also as non- schedule…

DEPUTY COMMISSIONER OF INCOME TAX, CIR-2(1)(1), BARODA vs. THE BHARUCH DIS CENT CO-OP BANK LTD., BHARUCH

ITA 296/SRT/2022[2013-14]Status: DisposedITAT Surat09 Jan 2023AY 2013-14

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 254(1)Section 36(1)(viia)

…debts is nothing but providing for bad and doubtful debts from the profit and loss accounts. The assessee also relied on the decision of Rural Electrification Corporation Limited (2009) 312 ITR 122 (AAR) and Delhi Tribunal in Power Finance Corporation (2006) 10 SOT 190 (Delhi). The assessee also stated that no such disallowance was made in AY 2007- 08 and 2008-09 in the assessment order passed under section 143(3). On DCIT Vs Bharuch Dist. Cent. Co-Op Bank ltd. the basis of afforesaid submission, the assessee claimed that they are eligible for deduction of 10% both as co-operative bank and also as non- schedule…

Power Finance Corpn. Ltd. v. Joint Commissioner of Income-tax, Special Range-22 (10 SOT 190) — Cited in 5 Judgments | BharatTax