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“Section 36(1)”

Section References (mined)Section 36Section 36(1)3,872 judgments

The decision most relied on for Section 36(1) is CIT v. Reliance Utilities & Power Ltd. (313 ITR 340), cited in 2,118 judgments on BharatTax.

Leading authorities on Section 36(1)

CIT v. Reliance Utilities & Power Ltd.
313 ITR 340 · 2009 · High Court
2,118
citing judgments

Where an assessee claims that investments were made out of own funds, interest disallowance under Section 14A read with Rule 8D may not apply if the assessee demonstrates the availability of sufficient interest-free funds to cover such investments.

CIT v. AIMIL Ltd.
321 ITR 508 · 2010 · High Court
1,629
citing judgments

Employee contributions to PF and ESIC, deposited beyond the due date under the respective Acts but within the due date for filing the income tax return under Section 139(1), are allowable deductions under Section 36(1)(va). Such disallowance cannot be made during processing under Section 143(1).

S.A. Builders Ltd. v. CIT
288 ITR 1 · 2007 · Supreme Court
1,484
citing judgments

Interest paid on borrowed funds cannot be disallowed merely because the assessee made interest-free advances, provided those advances were made for business purposes and commercial expediency. The Revenue cannot dictate a businessman's commercial decisions, but the assessee bears the onus to prove the business expediency.

Checkmate Services Pvt. Ltd. v. CIT
143 Taxmann.com 178 · 2022 · Supreme Court
1,392
citing judgments

Employee contributions to provident fund and ESI deposited by an employer beyond the due dates prescribed under the respective special Acts are not allowable as a deduction under section 36(1)(va) of the Income-tax Act, 1961. Such disallowance can be made during processing under section 143(1).

CIT v. Alom Extrusions Ltd.
319 ITR 306 · 2009 · Supreme Court
1,344
citing judgments

A proviso inserted into a section to remedy unintended consequences, make the section workable, or supply an obvious omission must be read retrospectively in operation to give effect to the section as a whole.

CIT v. HDFC Bank Ltd.
366 ITR 505 · 2014 · High Court
1,261
citing judgments

When an assessee possesses interest-free funds sufficient to cover investments yielding tax-free income, it is presumed that such investments were made from these interest-free funds, precluding disallowance of interest expenditure under Section 14A.

CIT v. Gujarat State Road Transport Corporation
366 ITR 170 · 2014 · High Court
1,158
citing judgments

Employees' contributions to welfare funds, such as provident fund, are not allowable as a deduction under section 36(1)(va) if deposited beyond the due date prescribed under the respective welfare statutes, even by a single day. Such delayed deposits are not cured even if made before the income-tax return filing due date.

TRF Ltd. v. CIT
323 ITR 397 · 2010 · Supreme Court
714
citing judgments

For claiming deduction for bad debts under section 36(1)(vii) of the Income Tax Act, it is sufficient for the assessee to write off the debt as irrecoverable in its accounts, and it is not necessary to prove that the debt has actually become irrecoverable.

Judgments citing Section 36(1)

JCIT(OSD), Range-10, New Delhi, C.R. Building ITO vs. Rural Electrification Corporation Ltd., Kasturba Nagar

ITA 609/DEL/2025[2020-21]Status: DisposedITAT Delhi12 Feb 2026AY 2020-21

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharmarec Limited, C/O D-22, Second Floor, South Extension 1, New Delhi – 110 049

For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

erred in granting relief to the assessee on the issue of the disallowance of Rs.5584,57,541/- under section 36(1)(vii) and section 36(1) (viia) (c) of the Act i.e., deductions under both section is independent on each other?" 4. Since the issue raised by the revenue ... remand report dated 07.03.2023 (PB Pg. 802 to 807) 2.3.3 To support our contention, we have reproduced herein below the relevant extract of Section 36(1)(viii) for your easy reference:- "In respect of any special reserve created and maintained by a specified entity, an amount not exceeding twenty percent

JCIT(OSD), Range-10, New Delhi, C.R. Building ITO vs. Rural Electrification Corporation Ltd., Kasturba Nagar

ITA 579/DEL/2025[2021-22]Status: DisposedITAT Delhi12 Feb 2026AY 2021-22

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharmarec Limited, C/O D-22, Second Floor, South Extension 1, New Delhi – 110 049

For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

erred in granting relief to the assessee on the issue of the disallowance of Rs.5584,57,541/- under section 36(1)(vii) and section 36(1) (viia) (c) of the Act i.e., deductions under both section is independent on each other?" 4. Since the issue raised by the revenue ... remand report dated 07.03.2023 (PB Pg. 802 to 807) 2.3.3 To support our contention, we have reproduced herein below the relevant extract of Section 36(1)(viii) for your easy reference:- 12 ITA Nos.319 & 320/Del/2025 ITA Nos.577& 578/Del/2025 ITA Nos.609& 579/Del/2025 "In respect of any special reserve created and maintained

JCIT(OSD), Range-10, New Delhi, Cr Building ITO vs. Rural Electrification Corporation Ltd., Kasturba Nagar

ITA 578/DEL/2025[2019-20]Status: DisposedITAT Delhi12 Feb 2026AY 2019-20

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

erred in granting relief to the assessee on the issue of the disallowance of Rs.5584,57,541/- under section 36(1)(vii) and section 36(1) (viia) (c) of the Act i.e., deductions under both section is independent on each other?" 4. Since the issue raised by the revenue ... remand report dated 07.03.2023 (PB Pg. 802 to 807) 2.3.3 To support our contention, we have reproduced herein below the relevant extract of Section 36(1)(viii) for your easy reference:- "In respect of any special reserve created and maintained by a specified entity, an amount not exceeding twenty percent

JCIT(OSD), Range-10, New Delhi, ITO C.R. Building vs. Rural Electrification Corporation Ltd., Kasturba Nagar

ITA 577/DEL/2025[2018-19]Status: DisposedITAT Delhi12 Feb 2026AY 2018-19

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharmarec Limited, C/O D-22, Second Floor, South Extension 1, New Delhi – 110 049

For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

erred in granting relief to the assessee on the issue of the disallowance of Rs.5584,57,541/- under section 36(1)(vii) and section 36(1) (viia) (c) of the Act i.e., deductions under both section is independent on each other?" 4. Since the issue raised by the revenue ... remand report dated 07.03.2023 (PB Pg. 802 to 807) 2.3.3 To support our contention, we have reproduced herein below the relevant extract of Section 36(1)(viii) for your easy reference:- 12 ITA Nos.319 & 320/Del/2025 ITA Nos.577& 578/Del/2025 ITA Nos.609& 579/Del/2025 "In respect of any special reserve created and maintained

Rec Limited, New Delhi vs. ACIT-10 (OSD), Delhi, New Delhi

ITA 320/DEL/2025[2019-20]Status: DisposedITAT Delhi12 Feb 2026AY 2019-20

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmarec Limited, C/O D-22, Second Floor, South Extension 1, New Delhi – 110 049

For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

erred in granting relief to the assessee on the issue of the disallowance of Rs.5584,57,541/- under section 36(1)(vii) and section 36(1) (viia) (c) of the Act i.e., deductions under both section is independent on each other?" 4. Since the issue raised by the revenue ... remand report dated 07.03.2023 (PB Pg. 802 to 807) 2.3.3 To support our contention, we have reproduced herein below the relevant extract of Section 36(1)(viii) for your easy reference:- 12 "In respect of any special reserve created and maintained by a specified entity, an amount not exceeding twenty

Rec Limited, New Delhi vs. ACIT-10 (OSD), Delhi, New Delhi

In the result, appeals filed by the revenue in the AY 2020-21 and AY

ITA 319/DEL/2025[2018-19]Status: DisposedITAT Delhi12 Feb 2026AY 2018-19

Bench: Shris.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Ashwani Taneja, AdvocateFor Respondent: Ms. Pooja Swroop, CITDR
Section 36(1)(vii)Section 36(1)(viia)Section 36(1)(viii)

erred in granting relief to the assessee on the issue of the disallowance of Rs.5584,57,541/- under section 36(1)(vii) and section 36(1) (viia) (c) of the Act i.e., deductions under both section is independent on each other ?” Since the issue raised by the revenue and assessee ... remand report dated 07.03.2023 (PB Pg. 802 to 807) 2.3.3 To support our contention, we have reproduced herein below the relevant extract of Section 36(1)(viii) for your easy reference:- 12 ITA Nos.319 & 320/Del/2025 ITA Nos.577& 578/Del/2025 ITA Nos.609& 579/Del/2025 “In respect of any special reserve created and maintained

E Factor Adventure Tourism Private Limited, Delhi vs. The DCIT, CC-13, Delhi

In the result, appeal of the assessee is partly allowed

ITA 3006/DEL/2025[2017-2018]Status: DisposedITAT Delhi12 Feb 2026AY 2017-2018

Bench: Shri Vikas Awasthy& Shri Brajesh Kumar Singhआअसं.3006/धिल्ली/2025(नि.व. 2017-18) E Factor Adventure Tourism P. Ltd., 101 A, Kundan Kutir, Hari Nagar, Ashram, New Delhi 110014 ...... अपीलार्थी/Appellant Pan: Aabce-7871-R बिाम Vs. Deputy Commissioner Of Income Tax, .....प्रनिवादी/Respondent Central Circle-13, New Delhi 110055 अपीलार्थी द्वारा/ Appellant By: Shri S.K Chaturvedi, Chartered Accountant प्रधििािीद्वारा/Respondent By: Shri Om Prakash, Sr. Dr सुिवाई की निथर्थ/ Date Of Hearing : 03/02/2026 घोषणा की निथर्थ/ Date Of Pronouncement : 03/02/2026 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Assessee Is Directed Against The Order Of Commissioner Of Income Tax-26, New Delhi [In Short ‘The Cit(A)’] Dated 06.03.2025, For Ay 2017-18 In Proceedings U/S.154 Of The Income Tax Act,1961(Hereinafter Referred To As ‘The Act’).

For Appellant: Shri S.K Chaturvedi, Chartered AccountantFor Respondent: Shri Om Prakash, Sr. DR
Section 143(3)Section 154Section 36(1)(va)

decision in “Checkmate Services Private Limited” (Supra), whereby the Supreme Court held that the deduction of the employees’ share can be allowed under Section 36(1)(va) of the IT Act, only if such share was deposited before the time limit under the respective statutes and not before

Raiganj Central Co-Operative Bank Ltd., Raiganj, Uttar Dinajpur vs. D, C, I.T., Circle - 2, Jalpaiguri

In the result, the appeal filed by the Revenue in ITA No

ITA 975/KOL/2024[2013-2014]Status: DisposedITAT Kolkata11 Feb 2026AY 2013-2014

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 115Section 143(3)Section 250Section 36(1)(viia)Section 40

justified by upholding the deletion of Panjipara Branch of the appellant from the list of Rural branches while calculating the deduction allowable under section 36(1)(viia) of the Income Tax Act, 1961. 8. THAT on the facts of the case, the Ld. CIT (Appeals)-NFAC, has erred ... list of Rural branches while calculating average outstanding of advances of rural branches to determine the maximum amount of deduction allowable under section 36(1)(viia) of the Income Tax Act, 1961. 10. THAT on the facts of the case, the Ld. CIT (Appeals)-NFAC, has grossly erred

Raiganj Central Co-Operative Bank Ltd., Raiganj, Uttar Dinajpur vs. D.C.I.T., Circle - 2, Jalpaiguri

ITA 974/KOL/2024[2012-2013]Status: DisposedITAT Kolkata11 Feb 2026AY 2012-2013

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 115Section 143(3)Section 250Section 36(1)(via)Section 36(1)(viia)Section 40

justified by upholding the deletion of Panjipara Branch of the appellant from the list of Rural branches while calculating the deduction allowable under section 36(1)(viia) of the Income Tax Act, 1961. 8. THAT on the facts of the case, the Ld. CIT (Appeals)-NFAC, has erred ... list of Rural branches while calculating average outstanding of advances of rural branches to determine the maximum amount of deduction allowable under section 36(1)(viia) of the Income Tax Act, 1961. 10. THAT on the facts of the case, the Ld. CIT (Appeals)-NFAC, has grossly erred

Raiganj Central Co-Operative Bank Ltd., Raiganj, Uttar Dinajpur vs. JCIT (TDS), Range - 6, Siliguri

ITA 2237/KOL/2024[2013-2014]Status: DisposedITAT Kolkata11 Feb 2026AY 2013-2014

Bench: Shri George Mathan & Shri Rakesh Mishra

Section 115Section 143(3)Section 250Section 36(1)(via)Section 36(1)(viia)Section 40

justified by upholding the deletion of Panjipara Branch of the appellant from the list of Rural branches while calculating the deduction allowable under section 36(1)(viia) of the Income Tax Act, 1961. 8. THAT on the facts of the case, the Ld. CIT (Appeals)-NFAC, has erred ... list of Rural branches while calculating average outstanding of advances of rural branches to determine the maximum amount of deduction allowable under section 36(1)(viia) of the Income Tax Act, 1961. 10. THAT on the facts of the case, the Ld. CIT (Appeals)-NFAC, has grossly erred

Tncp LLP., Coimbatore vs. ITO, Ncw-1(1), Coimbatore

ITA 2603/CHNY/2025[2018-19]Status: DisposedITAT Chennai11 Feb 2026AY 2018-19

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.:2602 & 2603/Chny/2025 निर्धारण वर्ष / Assessment Year: 2018-19 Tncd Llp, 126, Kg House, Arts College Road, Coimbatore - 641 018. [Pan:Aagft-8799-R] (अपीलार्थी/Appellant) अपीलार्थी की ओर से/Appellant By प्रत्यर्थी की ओर से/Respondent By Ito, Vs. Non Corporate Ward -1(1), Coimbatore. (प्रत्यर्थी/Respondent) : Shri. N. Arjun Raj, Advocate : Ms. R. Anitha, Addl.C.I.Τ. सुनवाई की तारीख/Date Of Hearing घोषण की तारीख/Date Of Pronouncement Per S. R. Raghunatha, Am: आदेश /Order : 20.11.2025 : 11.02.2026 These Appeals Of The Assessee Are Filed Against The Separate Orders Of The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, (In Short ‘Ld.Cit(A)') For The Assessment Year 2018-19, Both Dated 09.07.2025 Against The Assessment Orders Passed By The Ao, Nfac, Delhi, U/S.143 (3) R.W.S 144B Of The Income Tax Act, 1961 (In Short ‘The Act') Dated 20.09.2021 & The Penalty Order Passed By The Ao, Nfac, Delhi, U/S.270A Of The Act Dated 15.01.2022 Respectively. :-2-:

Section 142(1)Section 143Section 143(2)Section 23Section 23(1)Section 24Section 270ASection 36(1)(va)

from employee which were deposited by the assessee beyond the due date of making payment to such relevant funds within the meaning of section 36(1)(va) r.w.s 2(24)(x) of the Act as mentioned in point No.20(b) of Tax Audit Report. 7. The assessee responded

Tncd LLP., Coimbatore vs. ITO, Ncw-1(1), Chennai

In the result, the quantum appeal of the assessee in ITA

ITA 2602/CHNY/2025[2018-19]Status: DisposedITAT Chennai11 Feb 2026AY 2018-19

Bench: Shri Manu Kumar Giri & Shri S.R.Raghunathaआयकर अपील सं./Ita Nos.:2602 & 2603/Chny/2025 िनधा#रण वष# / Assessment Year: 2018-19 Tncd Llp, Ito, 126, Kg House, Vs. Non Corporate Ward -1(1), Arts College Road, Coimbatore. Coimbatore – 641 018. [Pan:Aagft-8799-R] (अपीलाथ%/Appellant) (&'थ%/Respondent) अपीलाथ% की ओर से/Appellant By : Shri. N. Arjun Raj, Advocate &'थ% की ओर से/Respondent By : Ms. R. Anitha, Addl.C.I.T. सुनवाई की तारीख/Date Of Hearing : 20.11.2025 घोषणा की तारीख/Date Of Pronouncement : 11.02.2026 आदेश /O R D E R

For Appellant: Shri. N. Arjun Raj, AdvocateFor Respondent: Ms. R. Anitha, Addl.C.I.T
Section 142(1)Section 143Section 143(2)Section 23Section 23(1)Section 24Section 270ASection 36(1)(va)

from employee which were deposited by the assessee beyond the due date of making payment to such relevant funds within the meaning of section 36(1)(va) r.w.s 2(24)(x) of the Act as mentioned in point No.20(b) of Tax Audit Report. 7. The assessee responded

India Infrastructure Finance Company Limited, Delhi vs. Assistant Commissioner of Income Tax, I.P. Estate, New Delhi

The appeal of the assessee is dismissed

ITA 5552/DEL/2024[2016-17]Status: DisposedITAT Delhi11 Feb 2026AY 2016-17

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

Section 115JSection 143(3)Section 154Section 250Section 36(1)Section 36(1)(vii)

position of law is well settled. After 1.4.1989, for allowing deduction for the amount of any bad debt or part thereof under section 36(1) (vii) of the Act, it is not necessary of assessee to establish that the debt, in fact these become irrecoverable; it is enough ... following observations:- 9. “I have considered the submission of the appellant. The appellant is a financial institution and as per the provisions of section 36(1) (viia) (c) of the Act, a public financial Institution is allowed an amount not exceeding 5% of the total income as provision

The Dakshin Dinajpur District Central Cooperative Bank Ltd., Balurghat vs. ACIT, Circle 3(2), Malda

In the result, all the appeals of the assessee are allowed

ITA 2189/KOL/2025[2014-2015]Status: DisposedITAT Kolkata10 Feb 2026AY 2014-2015

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Dilip Chatterjee, ARFor Respondent: Ms. Archana Gupta, DR
Section 36(1)(viia)

head other expenditure schedule-19 of the Profit and Loss account by ignoring the fact that same are allowable under Provisions of Section 36(1)(viia) of the Act and was created in accordance with the RBI and NABARD guidelines. 4.1. The facts in brief are that ... aggregated advances made by the rural branches of such bank computed in the prescribed manner. We have also perused the provisions of Section 36(1)(vii) of the Act, which provides for allowing the amount of any bad debt or a part thereof which is written off as irrecoverable

The Dakshin Dinajpur District Central Cooperative Bank Ltd., Balurghat vs. DCIT, Circle 3, Malda

In the result, all the appeals of the assessee are allowed

ITA 2188/KOL/2025[2013-2014]Status: DisposedITAT Kolkata10 Feb 2026AY 2013-2014

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Dilip Chatterjee, ARFor Respondent: Ms. Archana Gupta, DR
Section 36(1)(viia)

head other expenditure schedule-19 of the Profit and Loss account by ignoring the fact that same are allowable under Provisions of Section 36(1)(viia) of the Act and was created in accordance with the RBI and NABARD guidelines. 4.1. The facts in brief are that ... aggregated advances made by the rural branches of such bank computed in the prescribed manner. We have also perused the provisions of Section 36(1)(vii) of the Act, which provides for allowing the amount of any bad debt or a part thereof which is written off as irrecoverable

The Dakshin Dinajpur District Central Cooperative Bank Ltd., Balurghat vs. DCIT, Circle 3, Malda

In the result, all the appeals of the assessee are allowed

ITA 2187/KOL/2025[2012-2013]Status: DisposedITAT Kolkata10 Feb 2026AY 2012-2013

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm

For Appellant: Shri Dilip Chatterjee, ARFor Respondent: Ms. Archana Gupta, DR
Section 36(1)(viia)

head other expenditure schedule-19 of the Profit and Loss account by ignoring the fact that same are allowable under Provisions of Section 36(1)(viia) of the Act and was created in accordance with the RBI and NABARD guidelines. 4.1. The facts in brief are that ... aggregated advances made by the rural branches of such bank computed in the prescribed manner. We have also perused the provisions of Section 36(1)(vii) of the Act, which provides for allowing the amount of any bad debt or a part thereof which is written off as irrecoverable

Rohan Landscape Private Limited, Mumbai vs. The Principle Commissioner of Income Tax, Mumbai

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

ITA 3635/MUM/2025[2020-21]Status: DisposedITAT Mumbai10 Feb 2026AY 2020-21

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI ARUN KHODPIA (Accountant Member)

Section 139(1)Section 142(1)Section 143(2)Section 263Section 3

Rohan Landscape Private Limited only post-completion interest was claimed as revenue expenditure. It was emphasised that this treatment was in accordance with section 36(1)(iii) and accepted accounting principles. On other expenses and business expenditure, the assessee reiterated that these were revenue in nature and incurred wholly ... claimed as revenue expenditure. Interest on inter-corporate deposits was suo motu disallowed. This treatment is in consonance with section 36(1)(iii) and settled accounting principles. The learned Principal Commissioner has not identified any factual error in this treatment nor demonstrated that the Assessing Officer’s view is contrary

Income Tax Officer, Ward-6(1), New Delhi, I.P.. Estate vs. Continental Construction Ltd, Delhi

In the result, appeal of the Revenue is dismissed being devoid of any merit

ITA 3211/DEL/2025[2010-11]Status: DisposedITAT Delhi10 Feb 2026AY 2010-11

Bench: Shri Vikas Awasthy& Shri Brajesh Kumar Singhआअसं.3211/धिल्ली/2025(नि.व. 2010-11) Income Tax Officer, Ward-6(1), R. No.380 C, Third Floor, Cr Building, ...... अपीलार्थी/Appellant Ito, Delhi 110002 बिाम Vs. Continental Construction Ltd., 28, Continental House, Nehru Place, Delhi 110019 .....प्रनिवादी/Respondent Pan: Aaacc-2309-R अपीलार्थी द्वारा/ Appellant By: Shri Rajesh Chandra, Cit-Dr प्रधििािीद्वारा/Respondent By: S/Shri M.P Rastogi, Advocate & K. K Pandey सुिवाई की निथर्थ/ Date Of Hearing : 04/02/2026 घोषणा की निथर्थ/ Date Of Pronouncement : 04/02/2026 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Revenue Is Directed Against The Order Of Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi [In Short ‘The Cit(A)’] Dated 07.03.2025, For Ay 2010-11. 2. The Revenue In Appeal Has Assailed The Order Of Cit(A) In Deleting The Addition Of Rs.57,44,86,933/- On Account Of Writing Off Of Interest On Deferred Dues From Iraq.

For Appellant: Shri Rajesh Chandra, CIT-DRFor Respondent: S/Shri M.P Rastogi, Advocate & K. K Pandey

dispute regarding accrual of 4 interest on outstanding payments from Iraq and Libya. He further contended that the only requirement of section 36(1)(vii) of the Act is that the amount should be written off as irrecoverable in the books of account, the assessee is not required to establish ... reason to doubt that the assessee had executed civil contracts in Iraq and Libya, the dues of which remained outstanding. The provisions of section 36(1)(vii) of the Act are unambiguous as regards to the manner of writing off of bad debts. It is sufficient if the amount

Rituraj Steel Private Limited, Bilaspur vs. Assistant Commissioner of Income Tax Circle 2(1), Bilaspur

In the result, the appeal of assessee is allowed for statistical purposes

ITA 697/RPR/2025[2017-18]Status: DisposedITAT Raipur09 Feb 2026AY 2017-18

Bench: Shri Partha Sarathi Chaudhury, Jm & Shri Avdhesh Kumar Mishra, Am आयकर अपील सं. / Ita No: 697/Rpr/2025 (िनधा"रण वष" Assessment Year: 2017-18) Rituraj Steel Private Limited, M/S Vs Assistant Commissioner Of Income Rituraj Steel Private Limited, Hotel Tax, Circle 2(1), Bilaspur, East Park Agrasen Chowk, Shri Ram Plaza Vapar Vihar, Bilaspur, Chhattisgarh, 495001 Bilaspur, Chhattisgarh, 495001 Pan: Aaccr7589J (अपीलाथ"/Appellant) : (""थ" / Respondent) िनधा"रती की ओर से / Assessee By : None (Petition Filed) राज" की ओर से / Revenue By : Dr. Priyanka Patel, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 05/02/2026 घोषणा की तारीख / Date Of : 09/02/2026 Pronouncement आदेश / O R D E R Per Avdhesh Kumar Mishra, Am: This Appeal For Assessment Year (‘Ay’) 2017-18 Filed By The Assessee Is Directed Against The Order Dated 29.10.2025 Of The Additional Commissioner Of Income Tax (Appeals), Mysore [‘Addl. Cit(A)’] Passed Under Section 250 Of The Income Tax Act, 1961 (‘Act’).

For Appellant: None (Petition filed)For Respondent: Dr. Priyanka Patel, Sr. DR
Section 250Section 36(1)(iii)

sole effective issue raised by the appellant assessee is in respect of the disallowance of Rs.1,87,000/- made under section 36(1)(iii) of the Act, which reads as “the disallowance being unjustified, unwarranted and uncalled for when 1 Rituraj Steel Pvt Ltd. vs. ACIT(A), Bilaspur the paid ... Assessing Officer (‘AO’) made two disallowances: (i) Service Tax Penalty of Rs.14,19,967/- and; (ii) Interest of Rs.1,87,000/- under section 36(1)(iii) of the Act. We have been tasked to decide the issue of disallowance of interest under section 36(1)(iii) of the Act being

Ces Limited, Hyderabad vs. DCIT., Circle-1(1), Hyderabad

In the result, appeal of the Assessee is allowed for statistical purposes

ITA 638/HYD/2025[2018-19]Status: DisposedITAT Hyderabad06 Feb 2026AY 2018-19

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita.No.638/Hyd/2025 Assessment Year 2018-2019 Ces Limited, The Dcit, Circle-1(1), Hyderabad – 500 032. Vs. Hyderabad. Telangana. Telangana. Pan Aadcs4564P (Appellant) (Respondent) निर्धारिती द्वधिध/Assessee By : Ca P Murali Mohan Rao िधजस् व द्वधिध/Revenue By : Dr. Sachin Kumar, Sr. Ar सुिवधई की तधिीख/Date Of Hearing: 02.02.2026 घोषणध की तधिीख/Pronouncement: 06.02.2026 आदेश/Order Per Vijay Pal Rao:

For Appellant: CA P Murali Mohan RaoFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 139Section 143Section 143(1)Section 143(2)Section 143(3)Section 250Section 36(1)(va)

payment were made within the time limits prescribed in the Act. 5. The Ld. CIT(A) erred in making the additions not considering section 36(1)(va) r.w.s 43B of the Act, the expenditure is allowable if paid within due date of filing of return