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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)

Rajasthan State Ganganagar Sugar Mills Limited, Jaipur vs. ACIT, Jaipur

In the result the appeal of the assessee is partly allowed

ITA 279/JPR/2024[2017-18]Status: DisposedITAT Jaipur08 May 2025AY 2017-18

Bench: Him The Assessment Order Passed By Acit, Circle-6, Jaipur [ For Short Ao ] U/S 143

For Appellant: Sh. Saurav Harsh, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143Section 145ASection 36(1)(va)

before due date and consider the Finance Act 2021 amendment is illegal, bad in law and void-ab- initio, as amendment to section 36(1)(va) is only prospective in nature and not retrospective i.e. not related to relevant Assessment Year 2017-18. 3. First, we take up the appeal ... contribution within the prescribed time and therefore, an addition of Rs. 8,042 was made as in terms of provision of section 36(1)(va) r.w.s. 2(24(x) of the Act. 6. Contribution to state Renewal Fund Ld. AO noted that the assessee has debited

DCIT, Circle-6, Jaipur, Ncrb vs. Rajasthan State Ganganagar Sugar Mills Limited, Nehru Sehkar Bhawan, Jaipur

In the result the appeal of the assessee is partly allowed

ITA 235/JPR/2024[2017-18]Status: DisposedITAT Jaipur08 May 2025AY 2017-18

Bench: Him The Assessment Order Passed By Acit, Circle-6, Jaipur [ For Short Ao ] U/S 143

For Appellant: Sh. Saurav Harsh, AdvFor Respondent: Mrs. Anita Rinesh, JCIT-DR
Section 143Section 145ASection 36(1)(va)

before due date and consider the Finance Act 2021 amendment is illegal, bad in law and void-ab- initio, as amendment to section 36(1)(va) is only prospective in nature and not retrospective i.e. not related to relevant Assessment Year 2017-18. 3. First, we take up the appeal ... contribution within the prescribed time and therefore, an addition of Rs. 8,042 was made as in terms of provision of section 36(1)(va) r.w.s. 2(24(x) of the Act. 6. Contribution to state Renewal Fund Ld. AO noted that the assessee has debited

Narayankrupa Reality, Ahmedabad vs. The Pr. CIT-3, Ahmedabad

In the result, appeal filed by the assessee is dismissed

ITA 677/AHD/2024[2018-19]Status: DisposedITAT Ahmedabad08 May 2025AY 2018-19

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), SHRI T.R. SENTHIL KUMAR (Judicial Member)

For Appellant: Shri Aseem L Thakkar, A.RFor Respondent: Shri Rignesh Das, CIT. DR
Section 263Section 36(1)Section 37

admissibility of deduction of an expenditure debited to P&L account depends on the relevant provisions of the Income-tax Act and section 36(1) (iii) provides that expenditure on account of interest on money borrowed is allowable as deduction in computation of business income. The assessee has further submitted

Amj Land Holdings Ltd., Pune vs. Asstt. Director of Income Tax, CPC, Bengaluru

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

ITA 2415/PUN/2024[2021-2022]Status: DisposedITAT Pune07 May 2025AY 2021-2022

Bench: Shri R. K. Panda & Ms. Astha Chandraassessment Year : 2021-22 Amj Land Holdings Limited Asst. Director Of Income Tax, Vs. Thergaon, Pune – 411033 Cpc, Bengaluru Pan: Aabcp0310Q (Appellant) (Respondent) Assessee By : Shri Nikhil S Pathak Department By : Shri Ramnath P Murkunde Date Of Hearing : 05-05-2025 Date Of Pronouncement : 07-05-2025 O R D E R

For Appellant: Shri Nikhil S PathakFor Respondent: Shri Ramnath P Murkunde
Section 115JSection 154Section 36(1)(va)

order of the Ld. CIT(A) / NFAC, the assessee is in appeal before the Tribunal by raising the following grounds: 1. Disallowance under section 36(1)(va) amounting to Rs.64,469/- against late payment of Employees Contribution towards Provident Fund as per CPC order: (a) On the facts ... Income Tax (Appeals) legally erred in upholding the disallowance of Rs.64,469/- made by the Asstt. Director of Income Tax, CPC under section 36(1)(va) of the Income Tax Act without appreciating that no such disallowance was warranted on the facts of the case. (b) On the facts

Ushakiron Movies Private Limited, Ramoji Film City vs. ACIT., Circle-5(1), Hyderabad

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 541/HYD/2024[2017-18]Status: DisposedITAT Hyderabad07 May 2025AY 2017-18

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.541/Hyd/2024 (िनधा"रण वष"/Assessment Year: 2017-18) M/S. Ushakiron Movies (P) Ltd Vs. Acit Ramoji Film City, Hyderabad Circle 5 (1) Pan:Aaacu2689L Hyderabad (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Advocate V. Siva Kumar राज" व "ारा/Revenue By:: Dr. Sachin Kumar, Dr सुनवाई की तारीख/Date Of Hearing: 13/02/2025 घोषणा की तारीख/Pronouncement: 07/05/2025 आदेश/Order

For Appellant: Advocate V. Siva KumarFor Respondent: : Dr. Sachin Kumar, DR
Section 143(3)Section 28Section 36(1)(vii)Section 36(2)(i)

ITA No 541 of 2024 Ushakiran Movies P Ltd आयकर अपील"य अ"धकरण, हैदराबाद पीठ IN THE INCOME TAX

Kishna Ram, Sirmour Himachal Pradesh vs. Income Tax Officer Nahan, Nahan

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

ITA 1108/CHANDI/2024[2021-22]Status: DisposedITAT Chandigarh06 May 2025AY 2021-22

Bench: SHRI. LALIET KUMAR (Judicial Member)

For Appellant: Shri Laljee Agarjeet, C.A Ms. Meenu, AdvocateFor Respondent: Dr Ranjeet Kaur, Addl. CIT, Sr. DR
Section 139(1)Section 143(1)Section 36(1)(va)Section 43B

Form 3CD. The CPC noted that these contributions had been credited to the respective employees’ accounts after the due dates prescribed under section 36(1)(va) of the Act, and accordingly disallowed the deduction by making an adjustment in the intimation. 5. Aggrieved by the adjustment, the assessee filed ... before the Ld. CIT(A) contending that while there was a delay in depositing the employees’ contribution beyond the due dates specified under section 36(1)(va), the contributions were nevertheless deposited before the due date for filing the return of income under section 139(1). Relying on various judicial

Vishal Plastomers Pvt. Ltd., Ahmedabad vs. The Jt.CIT, Range-8, Ahmedabad

The appeal of the Revenue is dismissed

ITA 1782/AHD/2014[2009-10]Status: DisposedITAT Ahmedabad06 May 2025AY 2009-10

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), Ms. SUCHITRA KAMBLE (Judicial Member)

For Appellant: Shri Bandish Soparkar, ARFor Respondent: Shri Prathvi Raj Meena, CIT.DR &
Section 143(3)Section 14ASection 234ASection 250(6)Section 36(1)(va)Section 37(1)Section 40Section 41(1)

Rs.17,58,42,082/-. During assessment proceedings the assessee was asked to justify its claim in accordance with the provision of section 36(1)(vii) of the Act r.w.s. 36(2) of the Act, as to whether the bad debt related to amount treated as income ... consider the plea of the assessee and adjudicated the allowability of claim of the bad debts in terms of the provisions of section 36(1)(vii) r.w.s. 36(2) of the Act. The Ld. Counsel for the assessee has drawn our attention to various judicial decisions holding that business advances

The ITO, Ward-8(4), Ahmedabad vs. Vishal Plastomers Pvt. Ltd., Ahmedabad

The appeal of the Revenue is dismissed

ITA 1776/AHD/2014[2009-10]Status: DisposedITAT Ahmedabad06 May 2025AY 2009-10

Bench: SMT. ANNAPURNA GUPTA (Accountant Member), Ms. SUCHITRA KAMBLE (Judicial Member)

For Appellant: Shri Bandish Soparkar, ARFor Respondent: Shri Prathvi Raj Meena, CIT.DR &
Section 143(3)Section 14ASection 234ASection 250(6)Section 36(1)(va)Section 37(1)Section 40Section 41(1)

Rs.17,58,42,082/-. During assessment proceedings the assessee was asked to justify its claim in accordance with the provision of section 36(1)(vii) of the Act r.w.s. 36(2) of the Act, as to whether the bad debt related to amount treated as income ... consider the plea of the assessee and adjudicated the allowability of claim of the bad debts in terms of the provisions of section 36(1)(vii) r.w.s. 36(2) of the Act. The Ld. Counsel for the assessee has drawn our attention to various judicial decisions holding that business advances

Hipe Infrastructure Projects LLP, Bangalore vs. Assistant Commissioner of Income Tax, Circle-7(1)(1), Bangalore

In the result, appeal filed by the assessee is allowed

ITA 1338/BANG/2024[2018-19]Status: DisposedITAT Bangalore06 May 2025AY 2018-19

Bench: Shri. Laxmi Prasad Sahu & Shri. Soundararajan Kassessment Year :2018-19

For Appellant: Shri. Narendra Kumar Jain, AdvocateFor Respondent: Shri. Sunil Kumar Agarwal, CIT(DR)(ITAT), Bangalore
Section 143(2)Section 68Section 69

assessee has made provision for bad and doubtful debts of Rs.1,15,00,000/- and subsequently it has disallowed the same under section 36(1)(viia) of the Act while contributing the taxable income during the year. It was also noted that this provision of the Act is not applicable ... made on the prudential norms as decided by the management and while filing the return of income inadvertently, it was disallowed under section 36(1)(viia) of the Act. He also agreed that the provision of section 36(1)(viia) of Page 7 of 9 the Act is not applicable

Vijay Commercial Cooperative Bank Ltd, Rajkot vs. Additional/Joint/Deputy/Assistant Commissioner of Income Tax, Rajkot

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

ITA 862/RJT/2024[2017-18]Status: DisposedITAT Rajkot05 May 2025AY 2017-18

Bench: Dr. Arjun Lal Saini, Am. & Dinesh Mohan Sinha, Jm आयकरअपीलसं./Ita No. 862 /Rjt/ 2024 ("नधा"रणवष" / Assessment Year: (2017-18) Vijay Commercial Co- Vs. Additional/ Joint/ Deputy/ Assistant Operative Bank Ltd. Commissioner Of Income Tax Vijay Bhavan, Kanak Road, Aayakar Bhavan, Race Course Ring Rajkot – 360001 Road, Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaav3799C (Appellant) (Respondent) Appellant By : Shri J. R. Mankodi, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr सुनवाईक"तार"ख/ Date Of Hearing :11/02/2025 घोषणाक"तार"ख/Date Of Pronouncement :05/05/2025

For Appellant: Shri J. R. Mankodi, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 143(3)Section 147Section 36(1)Section 36(1)(va)

ORPORATION BANK LTD. v. ACIT 2017 has been upheld considering the late deposit of EPF being in violation of stipulation made in the section 36(1)(va) of the Income-tax Act, 1961. 5. The assessee filed an appeal against the impugned order of the Ld. CIT(A), dated ... regards February 2017 deposit, we request your honor not to consider the late deposit of PF contributions as default under provisions contained in section 36(1)(va) of the Income Tax Act, 1961, because of the above noted reason, the situation was beyond the control of the assessee as explained

M/S. Checkmate Facility & Electronic Solution Pvt. Ltd., Vadodara vs. The ACIT, Circle-1(1)(1), Vadodara

In the result, the appeal is partly allowed for statistical

ITA 1614/AHD/2024[2015-16]Status: DisposedITAT Ahmedabad05 May 2025AY 2015-16

Bench: S/Shri T.R. Senthil Kumar & Makarand V.Mahadeokar

For Appellant: Ms.Kinjal Shah, CAFor Respondent: Shri Prateek Sharma, Sr.DR
Section 115JSection 129Section 142(1)Section 143(3)Section 2(24)(x)Section 250Section 26ASection 36(1)(va)Section 43B

course of assessment proceedings, the AO made two additions: - Rs.12,785/- on account of delayed deposit of employees’ contribution to PF/ESIC, invoking section 36(1)(va) read with section 2(24)(x); and - Rs.1,14,75,362/- on account of mismatch between gross receipts shown in Form 26AS and that ... employees’ contribution was deposited beyond the due date prescribed under the respective welfare legislations and therefore, not allowable as per the provisions of section 36(1)(va). The AO placed reliance on the decision of the Hon’ble Gujarat High Court in the case of Gujarat State Road Transport Corporation

M/S Steel Strips Infrastructures Ltd., Chandigarh vs. ACIT, CC-II, Chandigarh

In the result, appeal of the Assessee is partly allowed

ITA 732/CHANDI/2018[2014-15]Status: DisposedITAT Chandigarh01 May 2025AY 2014-15

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY, AM आयकर अपील सं. / ITA No. 732 /Chd/2018 निर्धारण वर्ष / Assessment Year : 2014-15 M/s Steel Strips Ltd. बनाम The Asst. CIT Central Circle-II Chandigarh SCO 49-50, Sector 26, Chandigarh स्थायी लेखा सं./PAN NO: AACCS5077J प्रत्यर्थी / Respondent अपीलार्थी/Appellant निर्धारिती की ओर से / Assessee by : Shri Ashwani Kumar, C.A, Ms. Muska Garg, C.A राजस्व की ओर से / Revenue by : Shri Ved Parkash Kalia, Sr. DR सुनवाई की तारीख/ Date of Hea

For Appellant: Shri Ashwani Kumar, C.A and Ms. Muska Garg, C.AFor Respondent: Shri Ved Parkash Kalia, Sr. DR
Section 271(1)(c)Section 28Section 36(1)(vii)Section 36(2)(i)Section 37(1)

recession in the real estate sector. The assessee, therefore, wrote off the amount as irrecoverable and claimed it as a deduction under Section 36(1)(vii) or alternatively as a business loss under Section 37(1) read with Section 28 of the Act. It was stated that the advance ... satisfy the condition that expenditure must 3 be incurred during the relevant year for a claim under Section 37(1). Concluding that neither Section 36(1)(vii) nor Section 37(1) supported the assessee’s claim, the AO made an addition of Rs. 27,00,000/- to the returned income

The DCIT Circle-3(1)(2), Ahmedabad vs. M/S. Ram Agri Infra Structure India Pvt. Ltd, Ahmedabad

In the result, ITA No. 1733/Ahd/2019 is partly allowed for statistical purposes and cross objection no

ITA 1733/AHD/2019[2012-13]Status: DisposedITAT Ahmedabad01 May 2025AY 2012-13

Bench: Dr. B.R.R. Kumar & Ms. Suchitra Kambleassessment Year 2012-13

For Appellant: Shri Vijay Trivedi, A.RFor Respondent: Shri R.N. Dsouza, CIT-D.R
Section 142(1)Section 143(1)Section 143(2)Section 14ASection 36(1)(iii)Section 68

made addition of Rs. 1,73,123/- in respect of the claim of the assessee related to interest expenditure as per provisions of section 36(1)(iii) of the Act. The Assessing Officer made addition of Rs. 1,38,798/- towards interest relating to advance payment of commission. The Assessing ... interest free advance which were provided for non-business purpose or utilizing creating capital assets or in violation of the proviso to section 36(1) of the Act. The CIT(A) has not taken cognizance of the relevant records and this needs verification as the Assessing Officer also

Madhya Pradesh Madhya Kshetra Vidut Vitaran Co Ltd, Bhopal vs. The ITO 2(1), Bhopal

In the result, this appeal is allowed for statistical purpose

ITA 252/IND/2023[2014-15]Status: DisposedITAT Indore30 Apr 2025AY 2014-15

Bench: Shri B.M. Biyani & Shri Paresh M. Joshi

Section 143(3)Section 36Section 36(1)Section 37

from provision of doubtful debts into account and has disallowed and added back only the provision for doubtful debts. 6.3 As per section 36(1) (viia) of the I.T. Act the provision for bad and doubtful debts are allowed as deduction only for Schedules Banks, Public Financial Institutions and NBFCs ... debited to the Profit and Loss account during the relevant Financial Year. Therefore, in view of the above facts and the provisions of section 36(1)(viia) of the I.T. Act, the amount of Rs.47.31 crores disallowed by the AO is confirmed. This ground of appeal is hereby dismissed

Up Government Employees Welfare, Lucknow vs. ACIT, NFAC, Delhi

In the result appeals in ITA No

ITA 743/LKW/2024[2017-18]Status: DisposedITAT Lucknow30 Apr 2025AY 2017-18

Bench: Sh. Kul Bharat & Sh. Nikhil Choudharyita Nos.743 & 746/Lkw/2024 & Ita No. 30/Lkw/2024 A.Y. 2017-18 U.P. Government Employees Vs. Assessing Officer, Nfac Welfare, Lucknow Pan:Aaatu0957A (Appellant) (Respondent) Assessee By: None Revenue By: Sh. Manu Chaurasia, Cit (Dr) Date Of Hearing: 15.04.2025 Date Of Pronouncement: 30.04.2025 O R D E R Per Bench.: These Three Appeals Have Been Filed By The Assessee Against The Orders Passed By The Ld. Cit(A), Nfac On 23.10.2024, 28.10.2024 & 2.01.2024 In The Appeals Preferred Against The Assessment Order Under Section 143(3), The Penalty Order Under Section 271Aac(1) & The Penalty Order Under Section 270A. The Grounds Of Appeal In These Three Appeals Are As Under:-

For Appellant: NoneFor Respondent: Sh. Manu Chaurasia, CIT (DR)
Section 143(3)Section 2(24)(x)Section 234ASection 270ASection 271ASection 36(1)(va)Section 40Section 68

facts and add the employees contribution to PF amounting of Rs. 16263564/- as per the provisions of section 2(24)(x) read with section 36(1)(va) of the I.T. Act 1961. 9. A.O. has erred in imposing interest under section 234A, B, C, D. 10. The appellant craves leave

Rajdhani Nagar Sahkari Bank Ltd, Lucknow vs. Dy.CIT Range-6, Lucknow

In the result, both the appeals in ITA Nos

ITA 142/LKW/2024[2012-13]Status: DisposedITAT Lucknow30 Apr 2025AY 2012-13

Bench: Sh. Kul Bharat & Sh. Nikhil Choudhary

For Appellant: Sh. K.R. Rastogi, C.A. & Sh. ShubhamFor Respondent: Sh. Sanjeev Krishna Sharma, Addl CIT (DR)
Section 2(24)(x)Section 36(1)Section 36(1)(v)

Before the Id. CIT(A), it was submitted that due to a mistake, the assessee had not claimed statutory deduction under section 36(1)(viia) and 36(1)(viii) of the I.T. Act. However, it had made provisions for NPA of Rs.81,73,424/- and debited the same ... Rajdhani Nagar Sahkari Bank Ltd. the profit and loss account. The same was required for claiming the statutory deduction under section 36(1)(viia) and 36(1)(viii) of the Income Tax Act. It was submitted that the mistake for not claiming the specific deduction in the return was unintentional

Babian, Lucknow vs. Income Tax Officer (1), Lucknow-New

In the result, the appeal of the assessee is dismissed as withdrawn

ITA 167/LKW/2022[2019-20]Status: DisposedITAT Lucknow30 Apr 2025AY 2019-20

Bench: Shri Kul Bharat & Shri Nikhil Choudharybabian Income Tax Officer (1) V. B-155, Bhootnath Market, Lucknow New, Indira Nagar, Lucknow-226016. Pratyaksh Kar Bhawan, 57, Ram Tirath Marg, Lucknow-226001. Pan:Aacfb9247N (Appellant) (Respondent) Appellant By: Shri Devashish Mehrotra, Ca Respondent By: Shri. Sunil Kumar Rajwanshi, Addl Cit(Dr) Date Of Hearing: 23 04 2025 Date Of Pronouncement: 30 04 2025 O R D E R

For Appellant: Shri Devashish Mehrotra, CAFor Respondent: Shri. Sunil Kumar Rajwanshi, Addl
Section 143(1)(a)Section 36(1)(va)Section 43B

deduction. 4. That the Id. CIT(A) has misinterpreted the amendments made by the Finance Act, 2021 by adding the Explanation 2 in Section 36(1)(va) and Explanation 5 to Sec. 43B by treating the same to having retrospective effect which is contrary to the intent of the Legislature

Saumil Impex Private Limited, Mumbai vs. The Dy.CIT, Circle-4(1)(1), Ahmedabad

In the result, the appeal filed by the Assessee is allowed for statistical purpose

ITA 951/AHD/2023[2013-14]Status: DisposedITAT Ahmedabad30 Apr 2025AY 2013-14

Bench: Shri T.R. Senthil Kumar (Judicial Member), Shri Makarand Vasant Mahadeokar (Accountant Member)

Section 143(3)Section 145Section 234ASection 250Section 271(1)(c)Section 36(1)(iii)Section 69

case of the Appellant, the Ld. CIT(A)- NFAC had erred in confirming the addition of Rs. 23,34,933/- made under section 36(1)(iii) of the Act. 9. Without prejudice to above, in law and in the facts and circumstances the Ld. CIT(A)- NFAC erred in confirming

Icici Bank Ltd, Mumbai vs. Addl CIT RG 3 (1), Mumbai

ITA 4249/MUM/2014[2008-09]Status: DisposedITAT Mumbai30 Apr 2025AY 2008-09

Bench: Smt. Beena Pillai & Shri Omkareshwar Chidara

For Appellant: Arati VissanjiFor Respondent: Shri Ajay Chandra, CIT/DR
Section 10(15)Section 14ASection 250Section 36(1)(vii)Section 92C

Bank v. CIT & Anrs.323 ITR 166 have allowed the Appellant's claim for bad debts on the ground that after the amendment of section 36(1)(vii) w.e.f. April 1, 1989 if the debt has been written as irrecoverable in the accounts of the assessee, it will suffice for claiming

DCIT Cir 3(1), Mumbai vs. Icici Bank Ltd, Mumbai

ITA 4159/MUM/2014[2008-09]Status: DisposedITAT Mumbai30 Apr 2025AY 2008-09

Bench: Smt. Beena Pillai & Shri Omkareshwar Chidara

For Appellant: Arati VissanjiFor Respondent: Shri Ajay Chandra, CIT/DR
Section 10(15)Section 14ASection 250Section 36(1)(vii)Section 92C

Bank v. CIT & Anrs.323 ITR 166 have allowed the Appellant's claim for bad debts on the ground that after the amendment of section 36(1)(vii) w.e.f. April 1, 1989 if the debt has been written as irrecoverable in the accounts of the assessee, it will suffice for claiming