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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)

Arvind Chheda, Mumbai vs. DCIT 41(2)(1), Mumbai

In the result appeal filed by the assessee stands partly allowed

ITA 6649/MUM/2024[2020-21]Status: DisposedITAT Mumbai19 Feb 2025AY 2020-21

Bench: Smt. Beena Pillai ()

Section 143(1)Section 143(1)(a)Section 36(1)Section 36(1)(va)Section 43B

IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, MUMBAI BEFORE SMT. BEENA PILLAI (JUDICIAL MEMBER) I.T.A. No.6649/Mum/2024 Assessment Year: 2020

Parakkott Investment India Pvt Ltd, Mumbai vs. Income Tax Officer Ward 14(2)(4), Mumbai

In the result, no question of law arises

ITA 2137/MUM/2024[2017-18]Status: DisposedITAT Mumbai19 Feb 2025AY 2017-18

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2017-18

For Appellant: Shri M. Subramaniam, AdvocateFor Respondent: Shri Krishna Kumar, Sr. DR
Section 143(3)Section 14ASection 36

India Pvt. Ltd., AY 2017-18 3.3. After considering the submissions made by the assessee, ld. Assessing Officer analysed the provisions contained in section 36(1)(iii). He observed that assessee has utilised interest bearing funds for giving interest free loan to its associate company. According to him, assessee

Zenith Dyeintermediates Ltd, Mumbai vs. Principle CIT-3, Mumbai

In the result, appeal of the assessee is partly allowed

ITA 1999/MUM/2024[2017-18]Status: DisposedITAT Mumbai19 Feb 2025AY 2017-18

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

For Appellant: Shri Gaurav Bansal, A/RFor Respondent: Shri Dr. Kishor Dhule, CIT D/R
Section 143(3)Section 263Section 37(1)Section 4(1)Section 40

Report (Form No.3CD), it is observed from Clause No. 20b "details of contributions received from employees for various funds as referred to in section 36(1)(va)" that the assessee has paid Employees Contribution towards Provident Fund. As per provision of Income Tax Act, any sum received by the assessee

The Jackson Co Op Credit Society of the Employee of Western Railway Ltd, Mumbai vs. Deputy Commissioner of Income Tax - CPC, Bengaluru

In the result appeal filed by the assessee stands allowed

ITA 1244/MUM/2024[2018-19]Status: DisposedITAT Mumbai19 Feb 2025AY 2018-19

Bench: Smt. Beena Pillai ()

Section 139(1)Section 143(1)Section 143(1)(a)Section 36(1)(va)Section 43B

prima facie adjustment on account of delay in deposit of employees contribution towards Provident Fund, by relying upon the provisions of section 36(1)(va) of the I. T. Act, 1961, not appreciating that such deposit was made prior to the due date as per section 139(1) and that ... prima facie adjustment on account of delay in deposit of employees contribution towards Provident Fund, by relying upon the provisions of section 36(1)(va) of the I. T. Act, 1961, not appreciating that the concerned deposit was made prior to the due date for filing return as per section

Jitendra Shankerlal Brahmbhatt, Mumbai vs. Asstt Comm. of Income Tax, Mumbai

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

ITA 6705/MUM/2024[2018-19]Status: DisposedITAT Mumbai14 Feb 2025AY 2018-19

Bench: SHRI. OM PRAKASH KANT (Accountant Member), MS. KAVITHA RAJAGOPAL (Judicial Member)

For Appellant: Shri. Rahul HakkaniFor Respondent: Shri. Manish Saresh (CIT-DR)
Section 139(1)Section 143(2)Section 250Section 36(1)(iii)Section 40Section 68

without appreciating that said disallowance is not supported by 2 Jitendra Shankerlal Brahmbhatt the provisions of Section 36(1)(iii) and Assessee had sufficient interest free funds and the interest free advances were on the grounds of commercial expediency and hence, the disallowance

Mangaldeep Superstructures Private Limited, Mumbai vs. Income Tax Officer, National E Assessment Centre

In the result, the appeal of the assessee is partly allowed

ITA 5797/MUM/2024[2018-19]Status: DisposedITAT Mumbai14 Feb 2025AY 2018-19

Bench: Shri Rahul Chaudhary & Smt. Renu Jauhrimangaldeep V/S. Ito, Superstructures Pvt. Ltd. बनाम Delhi-110001 45 Heeramani Ratanbangur Nagar Goregaon West, Maharashtra-400104 स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aaaci771B Appellant/अपीलार्थी .. Respondent/प्रतिवादी

For Appellant: Letter fileFor Respondent: Shri. R. R. Makwana
Section 10Section 139(1)Section 143(1)Section 143(2)Section 143(3)Section 250

added to the income. 6.4 We have heard the rival submissions and perused the material placed before us. As per the provisions of section 36(1)(va), the employees’ contributions to PF and ESI have to be deposited by the due date prescribed

Puja Entertainment (India) Limited, Mumbai vs. Dy Commissioner of Income Tax, Central Circle -2(4), Mumbai

In the result, appeal of the assessee is allowed

ITA 3285/MUM/2023[2020-21]Status: DisposedITAT Mumbai13 Feb 2025AY 2020-21

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2020-21

For Appellant: Shri Dharan Gandhi, AdvocateFor Respondent: Shri Manish Ajudiya
Section 143(3)Section 28Section 36(1)(vii)Section 36(2)(i)Section 37(1)

Khyati Realtors (P.) Ltd. [2022] 141 taxmann.com 461/289 Taxman 60/447 ITR 167 (SC)/AIR 2022 SC 4030. to submit that Section 36(1) of the Act gives benefit to the assessee to claim a deduction on any bad debt or part thereof, which is written off as irrecoverable

Man Diesel and Turbo India Pvt. Ltd (As Successor of Man Turbo India Pvt.Ltd), Maharashtra vs. ACIT, Circle-2(1)(2), Vadodara

In the result, the appeal of the assessee is allowed in above terms

ITA 1319/AHD/2018[2013-14]Status: DisposedITAT Ahmedabad12 Feb 2025AY 2013-14

Bench: Smt.Annapurna Gupta & Ms. Suchitra Raghunath Kambleassessment Year : 2013-14 Man Diesel & Turbo India Vs. The Acit, Circle-2(1)(2) Pvt.Ltd. Vadodara. (As Successor Of Man Turbo India P. Ltd. E-73, Midc Area Waluj, Aurangabad Maharashtra 431 136. (Applicant) (Responent) Assessee By : Shri Rahul Mehta & Shri Pratik Vora, Ars. Revenue By : Shri Ankit Jain Sr.Dr सुनवाई क" तारीख/Date Of Hearing : 19/12/2025 घोषणा क" तारीख /Date Of Pronouncement: 12/02/2025 आदेश/O R D E R आदेश आदेश आदेश

For Appellant: Shri Rahul Mehta, and Shri Pratik Vora, ARsFor Respondent: Shri Ankit Jain Sr.DR
Section 143(2)Section 143(3)Section 2(24)Section 250(6)Section 36Section 36(1)(va)Section 37Section 43B

expenses of Rs.95,47,837/-; ii) Disallowance relating to the excess material consumed of Rs.1,95,45,952/-; iii) And disallowance under section 36(1)(va) of the Act of Rs.2,89,581/-. 4. The additions so made were challenged before the ld.CIT(A) who reduced the disallowance relating ... expenses to Rs.16,81,244/- and that on account of excess cost of material consumed to Rs.74,35,545/-. The disallowance made under section 36(1)(va) was upheld by him. 5. Aggrieved by the said order of the ld.CIT(A), the assessee has come up in appeal before

Intas Biopharmaceuticals Ltd., Ahmedabad vs. The Dy.Commissioner of Income Tax, R-2(1)(1), Ahmedabad

In the result, appeal of the assessee is partly allowed for statistical purpose

ITA 1035/AHD/2016[2012-13]Status: DisposedITAT Ahmedabad12 Feb 2025AY 2012-13

Bench: Ms. Suchitra Kamble & Shri Makarand Vasant Mahadeokarassessment Year: 2012-13

Section 14ASection 35Section 43B

Assessing Officer also made addition of Rs.3,44,20,356/- towards the expenses in relation to capitalized towards CWIT under Section 36(1)(iii) of the Act. The Assessing Officer further observed that the grant given by the DSIR is not in the nature of capital receipt

Agrawal Distilleries Pvt Ltd, Indore vs. Commissioner of Income Tax (Appeals), Delhi

In the result, appeal of the assessee Ground Nos 9 & 10 is allowed

ITA 1169/MUM/2024[2014-2015 (Q3)]Status: DisposedITAT Mumbai12 Feb 2025

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Percy J. Pardiwalla/wShriFor Respondent: Ms. Vatsala Jha(PCIT)
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 35ASection 36(1)(m)Section 37(1)Section 40Section 43(1)

learned AO/DRP has erred in disallowing interest expenses of Rs 26,45,28,627 on capital work-in- progress under section 36(1)(m) of the Act. 32. Without prejudice to Ground 3.1 above, on the facts and circumstances of the case and in law the learned AO/DRP has erred

Vodafone Digilink Ltd., New Delhi vs. DCIT, New Delhi

In the result, appeal of the assessee Ground Nos 9 & 10 is allowed

ITA 1169/DEL/2014[2009-10]Status: DisposedITAT Mumbai12 Feb 2025AY 2009-10

Bench: Shri Anikesh Banerjee & Shri Prabhash Shankar

For Appellant: Shri Percy J. Pardiwalla/wShriFor Respondent: Ms. Vatsala Jha (PCIT)
Section 143(3)Section 144CSection 144C(1)Section 144C(5)Section 35ASection 36(1)(m)Section 37(1)Section 40Section 43(1)

learned AO/DRP has erred in disallowing interest expenses of Rs 26,45,28,627 on capital work-in- progress under section 36(1)(m) of the Act. 32. Without prejudice to Ground 3.1 above, on the facts and circumstances of the case and in law the learned AO/DRP has erred

M/S Yum Restaurants (India) Pvt. Ltd., Gurgaon vs. ITO, New Delhi

In the result, appeal of the Revenue is dismissed and CO of the assessee is allowed

ITA 2369/DEL/2016[1999-00]Status: DisposedITAT Delhi11 Feb 2025AY 1999-00

Bench: Shri Vikas Awasthy & Shri S Rifaur Rahmanआअसं.1977/धिल्ली/2013(नि.व. 2009-10) Sahara India Commercial Corporation Ltd., Sahara India Sadan, 2A, Shakespeare Sarani, Kolkata 700071 ...... अपीलार्थी/Appellant Pan: Aadcs-6118-F बिाम Vs. Deputy Commissioner Of Income Tax, Central Circle-6, R. No. 334, E-2, Ara, ..... प्रनिवादी/Respondent Centre Jhandewalan Extn. New Delhi आअसं.4728, 2795, 4729, 4730 और 4731/धिल्ली/2017(नि.व. 2010-11 से 2014-15)

Section 142

claim by documentary evidences that the amounts written off had become unrecoverable. It is no more res integra that after amendment to section 36(1)(vii) of the Act, the assessee need not substantiate that the amounts are irrecoverable. The Hon’ble Apex Court in the case

Satish Prakash Agarwal, Agra vs. The ACIT, Circle 1(2)(1), Agra

In the result, appeal of the assessee is allowed

ITA 113/AGR/2021[2016-17]Status: DisposedITAT Agra07 Feb 2025AY 2016-17

Bench: : Shri Ramit Kocharassessment Year: 2016-17

Section 143(2)Section 143(3)Section 36(1)(iii)

made by the Ld. Assessing Officer even when the entire amount of interest expense on unsecured loans was allowable as deduction under section 36(1)(iii) of the Income-Tax Act, 1961 since the unsecured loans were utilized for making investment in the partnership firm from where income

Mr. Venkataraman Swaminathan, Chennai vs. ITO, Ncc-19(1), Chennai

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

ITA 2603/CHNY/2024[2017-18]Status: DisposedITAT Chennai07 Feb 2025AY 2017-18

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita No.2603/Chny/2024 निर्ाारण वर्ा /Assessment Years: 2017-18 Mr.Venkataraman Swaminathan, Income Tax Officer, No.28/1, Velu Street, Non.Corporate Circle-19(1), West Mambalam, Chennai. Chennai-600 033. [Pan: Aasps3855R] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : Shri D.Anand, Advocate. प्रत्यर्थी की ओर से /Revenue By : Ms.Anitha, Addl.Cit सुिवाई की तारीख/Date Of Hearing : 20.01.2025 घोर्णा की तारीख /Date Of Pronouncement : 07.02.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Shri D.Anand, AdvocateFor Respondent: Ms.Anitha, Addl.CIT
Section 250Section 36(1)Section 36(1)(iv)

flawed as he has confirmed the addition on wrong premise of ESI and PF being on the same putting for the purposes of section 36(1)(iv) r.w. rule 87. The Ld. DR vehemently supported the order of lower authorities. 3.0 We have heard rival submissions on the matter ... employer's contribution, if any, to any provident fund (whether recognized or not) in respect of the same employee for that year …” . Further, section 36(1)(iv) of the act provides as under:- (iv) “….any sum paid by the assessee as an employer by way of contribution towards a recognized

Assistant Commissioner of Income Tax, Ltu Circle -1, Chennai vs. Prudential Sugar Corporation Limited, Chitoor

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

ITA 2296/CHNY/2024[2017-18]Status: DisposedITAT Chennai07 Feb 2025AY 2017-18

Bench: Shri Ss Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./Ita No. 2296/Chny/2024 निर्ाारण वर्ा /Assessment Years: 2017-18 Asst. Commissioner Of Income Tax, Prudential Sugar Corporation Ltu Circle-1, Limited, Chennai. Prudential Nagar, Koppedu Post, Nindramandal, Andhra Pradesh-517587 [Pan: Aaacp4338D] (प्रत्यर्थी/Respondent) (अपीलार्थी/Appellant) अपीलार्थी की ओर से/ Assessee By : None प्रत्यर्थी की ओर से /Revenue By : Shri Nilay Baran Som, Cit सुिवाई की तारीख/Date Of Hearing : 07.01.2025 घोर्णा की तारीख /Date Of Pronouncement : 07.02.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: NoneFor Respondent: Shri Nilay Baran Som, CIT
Section 250Section 36(1)Section 37

Ld.AO an opportunity to examine the same. The Ld. DR informed that in this case the assessee had made claims qua provisions of section 36(1) (va), under section 37 as well as had shown current liabilities of substantial amounts, in respect of which no satisfactory details were filed before

Solvay Specialities India Private Limited, Mumbai vs. The Assistant Commissioner of Income Tax, Circle 16(2) / Assessment Unit, NFAC, Mumbai

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

ITA 6686/MUM/2024[2021-22]Status: DisposedITAT Mumbai07 Feb 2025AY 2021-22

Bench: MS. KAVITHA RAJAGOPAL (Judicial Member), SHRI. GIRISH AGARWAL (Accountant Member)

For Appellant: Shri. DhavalFor Respondent: Shri. Pravin Salunkhe, Sr. DR
Section 143(3)Section 153Section 92CSection 92C(3)

erred in making disallowance /addition of INR 1,00,31,282 [INR 89,92,702 under Section 36(1)(va) of the Act and INR 10.38,580 presumably under Section 41 of the Act] in the impugned order by adopting loss of INR 96,67,71,539 as the starting ... 1,00,31,282 made in the impugned order. 6. Erroneous disallowance of employee contribution to provident fund/ESI/any other welfare fund under section 36(1)(va) of the Act of INR 89,92,702 6.1 Without prejudice to the ground 5 above, on facts and circumstances of the case

Viiking Media and Entertainment Pvt. Ltd, Mumbai vs. Deputy Commissioner of Income Tax, Central Circle 2(2), Mumbai

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

ITA 6034/MUM/2024[2017-18]Status: DisposedITAT Mumbai07 Feb 2025AY 2017-18

Bench: Ms. Kavitha Rajagopal, Jm & Shri. Girish Agarwal, Am Viiking Media & Entertainment Deputy Commissioner Of Income Pvt. Ltd. Tax, Central Circle 2(2), Mumbai 604-605, 6Th Floor, Gateway Plaza, 604-605, 6Th Floor, Gateway Plaza, Vs. Central Circle 2(2), Mumbai – 400076. Central Circle 2(2), Mumbai – 400076. Pan/Gir No. Aaacj9884E (Assessee) : (Respondent) Assessee By : Shri. Aakash Kumar Respondent By : Shri. Ajay Singh, Sr Dr Date Of Hearing : 06.02.2025 Date Of Pronouncement : 07.02.2025 O R D E R Per Kavitha Rajagopal, J M: This Appeal Has Been Filed By The Assessee, Challenging The Ex Parte Order Of The Learned Commissioner Of Income Tax (Appeals) 52, Mumbai (‘Ld. Cit(A) For Short), National Faceless Appeal Centre (‘Nfac’ For Short) Passed U/S.250 Of The Income Tax Act, 1961 (‘The Act'), Pertaining To The Assessment Year (‘A.Y.’ For Short) 2017-18. 2. It Is Observed That The Present Appeal Has Been Filed With A Delay Of 16 Days For Which The Accountant Of The Ld.Ar Appearing For The Assessee Has Filed Application Dated 06.02.2025 Along With An Affidavit For Condoning The Said Delay. Upon Perusal Of The Same, We Deem It Fit To Hold That The Assessee Had “Sufficient Cause” For The Said Delay M/S. Viiking Media & Entertainment Pvt. Ltd. & Therefore We Are Inclined To Condone The Delay Caused By The Assessee In Filing The Present Appeal. Delay Condoned.

For Appellant: Shri. Aakash KumarFor Respondent: Shri. Ajay Singh, SR DR
Section 115JSection 143(2)Section 143(3)Section 250Section 36(1)(va)Section 68

erred in upholding the action of the Assessing Officer in making a disallowance of Rs 6,60,141 under section 36(1)(va) on account of delayed payment of employee's contribution to provident fund. The appellants contend that on the facts and in the circumstances of the case

Late Smt. Dayawanti Devi, New Delhi vs. DCIT, New Delhi

In the result, this assessee’s appeal is partly allowed for

ITA 1262/DEL/2014[2005-06]Status: DisposedITAT Delhi07 Feb 2025AY 2005-06

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwal

For Appellant: Shri J.P. Sharma, AdvFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 139(1)Section 143(1)Section 36(1)Section 40

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘F’, NEW DELHI Before Shri Satbeer Singh Godara, Judicial Member And Shri

Baroda Rajasthan Kshetriya Gramin Bank, Ajmer vs. Dy. CIT (ACIT) Circle -2 Ajmer, Cr Building, Opp. Session Court, Jaipur Road, Ajmer

In the result, the appeal of the assessee is dismissed

ITA 635/JPR/2024[2020-21]Status: DisposedITAT Jaipur06 Feb 2025AY 2020-21

Bench: Shri Gagan Goyal & Shri Narinder Kumarbaroda Rajasthan Kshetriya Gramin Bank, 2343 Rajasthan Patrika Building, Vaishali Nagar, Ajmer – 305004 Pan No. Aaajb1164C ...... Appellant

For Appellant: Mr. Shailesh Mantri, CA, Ld. ARFor Respondent: Mr. Arvind Kumar, CIT, Ld. DR
Section 22Section 23ASection 250Section 32Section 36(1)Section 43BSection 80PSection 80P(2)(a)Section 80P(4)

IN THE INCOME TAX APPELLATE TRIBUNAL JAIPUR BENCH “A”, JAIPUR BEFORE SHRI GAGAN GOYAL, ACCOUNTANT MEMBER AND SHRI NARINDER KUMAR

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

In the result, the captioned appeals by the revenue are dismissed and the cross-objections filed by the assessee are allowed

ITA 3164/MUM/2023[2013-14]Status: DisposedITAT Mumbai05 Feb 2025AY 2013-14

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

For Appellant: Shri Rakesh Joshi, A/RFor Respondent: Shri Mahesh Akhade, CIT D/R
Section 1Section 115JSection 143(3)Section 147Section 148Section 36(1)Section 36(1)(vii)Section 36(1)(viia)

made by the assessee in the books of account subject to limit of 5% of total income in accordance with the provisions of section 36(1) (viia)(c) of the Act. Section 36(1)(viia)(c) provides that an assessee being a public financial institution or a state financial corporation ... entire claim for bad debts write off is allowable to the assessee in light of detailed note enclosed on applicability of proviso to Section 36(1)(vii) r.w.s. 36(1)(vita)(c) of the Act as Annexure 2 for your kind perusal. Your goodself will appreciate that assessee has rightly