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“Section 36(1)(viia)”

Section References (mined)Section 36Section 36(1)(viia)445 judgments

The decision most relied on for Section 36(1)(viia) is Maxopp Investment Ltd. v. CIT (347 ITR 272), cited in 516 judgments on BharatTax.

Leading authorities on Section 36(1)(viia)

Maxopp Investment Ltd. v. CIT
347 ITR 272 · 2012 · High Court
516
citing judgments

Disallowance under Section 14A cannot exceed the exempt income earned. The Assessing Officer must record satisfaction regarding the assessee's accounts before making any disallowance.

South Indian Bank Ltd. v. CIT
438 ITR 1 · 2021 · Supreme Court
508
citing judgments

The mixed fund theory is affirmed, holding that no disallowance of interest expenditure under Section 14A can be made if the assessee possesses sufficient non-interest bearing funds, such as capital and reserves, to cover investments made in tax-free securities.

Vijaya Bank v. CIT
323 ITR 166 · 2010 · Supreme Court
392
citing judgments

A provision for bad and doubtful debts debited to the profit and loss account and reduced from advances on the balance sheet constitutes a write-off for deduction purposes. This is true even if individual debtor accounts are not closed.

Southern Technologies Ltd. v. JCIT
320 ITR 577 · 2010 · Supreme Court
353
citing judgments

The case concerns the allowability of deductions for provisions made under Section 36 of the Income Tax Act, 1961, especially those related to bad and doubtful debts. It distinguishes such deductions from the recognition of interest income on non-performing assets (NPAs).

Calcutta Co. Ltd. v. CIT
37 ITR 1 · 1959 · Supreme Court
341
citing judgments

When following the mercantile system of accounting, provisions for liabilities made on a scientific and rational basis are allowable as deductions, even if their actual quantification and discharge are deferred to a future date.

Catholic Syrian Bank Ltd. v. CIT
343 ITR 270 · 2012 · Supreme Court
326
citing judgments

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.

United Commercial Bank v. CIT
240 ITR 355 · 1999 · Supreme Court
314
citing judgments

Liabilities accrued on a notional basis are allowable as deductions under the mercantile system of accounting even if their exact quantification or discharge is deferred to a future date or if the demand itself is disputed.

M.M.Aqua Technologies Limited v. CIT
436 ITR 582 · 2021 · Supreme Court
308
citing judgments

Amendments to tax law that impose new obligations or change existing legal positions apply prospectively, even if stated to be "for the removal of doubts." The judgment also clarifies that deductions under Section 43B are allowed only on actual payment, overriding the mercantile system of accounting.

Judgments citing Section 36(1)(viia)

State Bank of India, Mumbai vs. Principle Commissioner of Income Tax-2, Mumbai

ITA 1533/MUM/2023[2019-20]Status: DisposedITAT Mumbai28 Aug 2024AY 2019-20

Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm

For Appellant: Shri Ketan Ved &For Respondent: Shri Dr. Kishor Dhule, CIT DR
Section 143(3)Section 144BSection 263

IN THE INCOME TAX APPELLATE TRIBUNAL “G” BENCH, MUMBAI BEFORE SHRI PRASHANT MAHARISHI, AM AND SHRI PAVAN KUMAR GADALE, JM

The National Bank for Agriculture and Rural Development, Mumbai vs. Deputy Commissioner of Income-Tax, Circle 3(2)(1), Mumbai, Aayakar Bhawan

In the result, the appeals of the assessee for AY 2018-19 and AY 2019-20

ITA 2481/MUM/2024[2019-20]Status: DisposedITAT Mumbai26 Aug 2024AY 2019-20

Bench: Ms Padmavathy S, Am & Shri Sunil Kumar Singh, Jm Ι.Τ.Α. No. 2480 /Mum/2024 (Assessment Year: 2018-19) Ι.Τ.Α. No. 2481 /Mum/2024 (Assessment Year: 2019-20) The National Bank Of Agriculture & Rural Development C-24, G Block, Bandra Kurla Complex, Bandra (E), Mumbai-400051. Pan : Aaact4020G Vs. Dcit, Circle-3(2)(1), Aaykar Bhavan, M.K. Road, Mumbai-400020. Appellant) : Respondent) Appellant/Assessee By : Shri J.D. Mistry, Sr. Adv. & Shri Niraj Sheth & Shri Gunjan Kakkad, Ar Revenue/Respondent By : Shri S. Srinivasu, Cit-Dr Date Of Hearing : 21.08.2024 Date Of Pronouncement : 26.08.2024 Order Per Padmavathy S, Am: These Appeals By The Assessee Are Against The Separate Orders Of The Principal Commissioner Of Income Tax, Mumbai 3 [In Short 'The Pcit'] Passed Under Section 263 Of The Income Tax Act, 1961 (The Act) Dated 14.03.2024 For

For Appellant: Shri J.D. Mistry, Sr. Adv. &For Respondent: Shri S. Srinivasu, CIT-DR
Section 143(3)Section 263Section 36(1)(vii)Section 36(1)(viia)

both the AYs are as below: (i) Validity of order under section 263. (ii) Non-allowance of provision for standard assets under section 36(1)(viia) (c) of the Act [without prejudice to (i)] The assessee company was formed as an autonomous body by an Act of Parliament ... debited an amount of Rs. 186,13,11,000/- towards provision for standard assets which has been claimed as a deduction under section 36(1)(viia). The PCIT further noticed that similar claim is made for an amount of Rs. 43,04,00,658/- for AY 2019-20. PCIT

The National Bank for Agriculture and Rural Development, Mumbai vs. The Deputy Commissioner of Income-Tax, Circle 3(2)(1), Mumbai

In the result, the appeals of the assessee for AY 2018-19 and AY 2019-20

ITA 2480/MUM/2024[2018-19]Status: DisposedITAT Mumbai26 Aug 2024AY 2018-19

Bench: Ms Padmavathy S, Am & Shri Sunil Kumar Singh, Jm

For Respondent: Shri S. Srinivasu, CIT-DR
Section 143(3)Section 263Section 36(1)(vii)Section 36(1)(viia)

both the AYs are as below: (i) Validity of order under section 263. (ii) Non-allowance of provision for standard assets under section 36(1)(viia) (c) of the Act [without prejudice to (i)] 2. The assessee company was formed as an autonomous body by an Act of Parliament ... debited an amount of Rs. 186,13,11,000/- towards provision for standard assets which has been claimed as a deduction under section 36(1)(viia). The PCIT further noticed that similar claim is made for an amount of Rs. 43,04,00,658/- for AY 2019-20. PCIT

Punjab State Coop. Bank Ltd., Chandigarh vs. ACIT, Cl-2(1), Chandigarh

In the result the impugned order of Ld

ITA 293/CHANDI/2023[2013-14]Status: DisposedITAT Chandigarh21 Aug 2024AY 2013-14

Bench: SHRI. VIKRAM SINGH YADAV (Accountant Member), SHRI. PARESH M. JOSHI (Judicial Member)

For Appellant: Shri Atul Goyal, C.AFor Respondent: Shri Dharam Vir, JCIT, Sr. DR
Section 143(1)Section 143(2)Section 250Section 253Section 80P(2)(a)

respect of Prudential norms on Income Recognition, Asset Classification and Provisioning pertaining to Advances" in the books o faccounts. Under the provisions of Section 36(1)(viia) of the Income Tax Act 1961the provisions so created in the books of the assessee is restricted ... only debits to the profit and loss account the proportion of the provision for bad debts which is allowable under the provisions of Section 36(1)(viia) of the Income Tax Act and the remaining amount is directly debited to the retained earnings of the assessee banking society. Therefore

Deputy Commissioner of Income Tax, Amravati & Chandrapur Circle, Amravati vs. Chandrapur District Central Co-Op Bank Ltd., Chandrapur

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

ITA 89/NAG/2022[2018-19]Status: DisposedITAT Nagpur21 Aug 2024AY 2018-19

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mahavir AtalFor Respondent: Shri Kailash C. Kanojiya
Section 143(3)Section 271(1)(c)Section 274Section 36(1)(viia)

assessment year 2013–14, declaring total loss of ` 28,47,56,893, claiming refund of ` 2,10,47,680, after claiming deduction under section 36(1)(viia) of the Income Tax Act, 1961 ("the Act") amounting to ` 46,57,11,248. Subsequently, the assessee filed revised return of income ... 30/109/2014, declaring total loss of ` 28,47,56,893, and claimed refund of ` 2,10,47,680, after claiming deduction under section 36(1)(viia) of the Act amounting tors 46,57,11,248. The case was selected for scrutiny. By following due process, the assessment was completed under section

ACIT, Chandrapur Circle, Chandrapur vs. Chandrapur Distt. Central Co-Op Bank Ltd, Chandrapur

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

ITA 399/NAG/2019[2015-16]Status: DisposedITAT Nagpur21 Aug 2024AY 2015-16

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mahavir AtalFor Respondent: Shri Kailash C. Kanojiya
Section 143(3)Section 271(1)(c)Section 274Section 36(1)(viia)

assessment year 2013–14, declaring total loss of ` 28,47,56,893, claiming refund of ` 2,10,47,680, after claiming deduction under section 36(1)(viia) of the Income Tax Act, 1961 ("the Act") amounting to ` 46,57,11,248. Subsequently, the assessee filed revised return of income ... 30/109/2014, declaring total loss of ` 28,47,56,893, and claimed refund of ` 2,10,47,680, after claiming deduction under section 36(1)(viia) of the Act amounting tors 46,57,11,248. The case was selected for scrutiny. By following due process, the assessment was completed under section

Assistant Commissioner of Income Tax, Chandrapur Circle, Chandrapur vs. M/S Chandrapur District Central Co-Oprative Bank Limted, Chandrapur

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

ITA 241/NAG/2018[2013-14]Status: DisposedITAT Nagpur21 Aug 2024AY 2013-14

Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member

For Appellant: Shri Mahavir AtalFor Respondent: Shri Kailash C. Kanojiya
Section 143(3)Section 271(1)(c)Section 274Section 36(1)(viia)

assessment year 2013–14, declaring total loss of ` 28,47,56,893, claiming refund of ` 2,10,47,680, after claiming deduction under section 36(1)(viia) of the Income Tax Act, 1961 ("the Act") amounting to ` 46,57,11,248. Subsequently, the assessee filed revised return of income ... 30/109/2014, declaring total loss of ` 28,47,56,893, and claimed refund of ` 2,10,47,680, after claiming deduction under section 36(1)(viia) of the Act amounting tors 46,57,11,248. The case was selected for scrutiny. By following due process, the assessment was completed under section

JCIT(OSD) Corporate Circle-1(1), Chennai vs. M/S Cholamandalam Investment and Fiance Comppany Limited, Chennai

In the result, the appeals filed by the assessee in ITA

ITA 515/CHNY/2023[2018-19]Status: DisposedITAT Chennai14 Aug 2024AY 2018-19

Bench: Shri Mahavir Singhand Shri S.R. Raghunatha

For Appellant: Shri Ajit Jain, CA (Through Virtual)For Respondent: Shri Nilay Baran Som, CIT
Section 143(3)

excess deduction in relation to provision for bad and doubtful debts amounting to INR 13,87,96,281 under the provisions of section 36(1)(viia)of the Act. On the facts and in the circumstances of the case, and in law, the learned CIT(A) has erred in upholding ... covered under section 36(i(viia) of the Act and thus to be ignored while computing the threshold for the purpose of section 36(1)(viia) of the Act. On considering the actual amount of provision for bad and doubtful debts, the threshold limit shall stand

JCIT(OSD) Corporate Circle-1(1), Chennai vs. M/S Cholamandalam Investment and Fiance Comppany Limited, Chennai

In the result, the appeals filed by the assessee in ITA

ITA 514/CHNY/2023[2017-18]Status: DisposedITAT Chennai14 Aug 2024AY 2017-18

Bench: Shri Mahavir Singhand Shri S.R. Raghunatha

For Appellant: Shri Ajit Jain, CA (Through Virtual)For Respondent: Shri Nilay Baran Som, CIT
Section 143(3)

excess deduction in relation to provision for bad and doubtful debts amounting to INR 13,87,96,281 under the provisions of section 36(1)(viia)of the Act. On the facts and in the circumstances of the case, and in law, the learned CIT(A) has erred in upholding ... covered under section 36(i(viia) of the Act and thus to be ignored while computing the threshold for the purpose of section 36(1)(viia) of the Act. On considering the actual amount of provision for bad and doubtful debts, the threshold limit shall stand

Cholamandalam Investment &Finance Company Limited, Parrys, Chennai vs. ACIT- Corporate Circle -1(2), Chennai

In the result, the appeals filed by the assessee in ITA

ITA 384/CHNY/2023[AY 2017-2018]Status: DisposedITAT Chennai14 Aug 2024

Bench: Shri Mahavir Singhand Shri S.R. Raghunatha

For Appellant: Shri Ajit Jain, CA (Through Virtual)For Respondent: Shri Nilay Baran Som, CIT
Section 143(3)

excess deduction in relation to provision for bad and doubtful debts amounting to INR 13,87,96,281 under the provisions of section 36(1)(viia)of the Act. On the facts and in the circumstances of the case, and in law, the learned CIT(A) has erred in upholding ... covered under section 36(i(viia) of the Act and thus to be ignored while computing the threshold for the purpose of section 36(1)(viia) of the Act. On considering the actual amount of provision for bad and doubtful debts, the threshold limit shall stand

M/S Cholamandalam Investment & Finance Company Limited, Chennai vs. DCIT-1(2), Chennai

In the result, the appeals filed by the assessee in ITA

ITA 847/CHNY/2020[2012-13]Status: DisposedITAT Chennai14 Aug 2024AY 2012-13

Bench: Shri Mahavir Singhand Shri S.R. Raghunatha

For Appellant: Shri Ajit Jain, CA (Through Virtual)For Respondent: Shri Nilay Baran Som, CIT
Section 143(3)

excess deduction in relation to provision for bad and doubtful debts amounting to INR 13,87,96,281 under the provisions of section 36(1)(viia)of the Act. On the facts and in the circumstances of the case, and in law, the learned CIT(A) has erred in upholding ... covered under section 36(i(viia) of the Act and thus to be ignored while computing the threshold for the purpose of section 36(1)(viia) of the Act. On considering the actual amount of provision for bad and doubtful debts, the threshold limit shall stand

Pragati Power Corporation Ltd, New Delhi vs. ACIT, Circle 20(1), New Delhi

In the result, the appeal filed by the assessee is partly allowed as indicated above

ITA 1617/DEL/2023[2018-19]Status: DisposedITAT Delhi14 Aug 2024AY 2018-19

Bench: SHRI S.RIFAUR RAHMAN (Accountant Member), SHRI SUDHIR PAREEK (Judicial Member)

Section 115JSection 145(2)Section 32Section 36Section 36(1)(iii)Section 37Section 43ASection 46ASection 80I

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘F’: NEW DELHI BEFORE, SHRI S.RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI SUDHIR

M/S Syndicate Bank, Manipal vs. Deputy Commissioner of Income Tax, Circle - 1, Udupi

In the result, appeal of the revenue in ITA No

ITA 1219/BANG/2019[2015-16]Status: DisposedITAT Bangalore08 Aug 2024AY 2015-16

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment Year: 2015-16

For Appellant: Shri S. Ananthan, A.RFor Respondent: Ms. Neera Malhotra, D.R
Section 115JSection 36(1)(vii)Section 36(1)(viia)

36(1)(vii) r.w.s. 36(2)(v) r.w.s. 36(1 3.1 The assessee bank relying on the Hon'ble Supreme Court decision that Section 36(1)(viia) is applicable only to rural advances in the case of Catholic Syrian Bank, contended that since no deduction is allowed for non-rural ... No.1219/Bang/2019 & ITA No.186/PAN/2019 Canara Bank (Erstwhile Syndicate Bank), Bangalore Page 4 of 32 introduction of explanation. Further it contended that since Section 36(1)(viia) applies only to rural debts, in the case of banks having rural branches, it is only rural debts which are to be adjusted against

Kotak Mahindra Bank Limited, Mumbai vs. Add/Joint/Deputy/ACIT, National E-Assessment Centre, Delhi

In the result, ground no. 1 raised by the revenue is

ITA 569/MUM/2023[2017-18]Status: DisposedITAT Mumbai08 Aug 2024AY 2017-18

Bench: Shri Amit Shuklaand

For Appellant: Shri Biswanath Das, Ld. DRFor Respondent: Shri Faroog Irani, Ld. AR
Section 250Section 36(1)Section 36(1)(vii)Section 36(2)(ii)Section 36(2)(viia)

allowing provision on standard assets of Rs. 41.36 cr. when in fact standard assets are neither bad not doubtful as required by section 36(1) (viia) of the Act." 4 "On the facts and in the circumstances of the case und in law, the Ld. CIT (A) erred in deleting ... allowing provision on standard assets of Rs. 41.36 crs. When in fact standard assets are neither bad nor doubtful as required by section 36(1) (viia) of the Act 8. On the facts and in the circumstances of the case and in law, the Ld. CITIA) erred in deleting

DCIT-2(3)(1), Mumbai vs. Kotak Mahindra Bank Limited, Mumbai

In the result, ground no. 1 raised by the revenue is

ITA 4056/MUM/2023[2012-13]Status: DisposedITAT Mumbai08 Aug 2024AY 2012-13

Bench: Shri Amit Shuklaand

For Appellant: Shri Biswanath Das, Ld. DRFor Respondent: Shri Faroog Irani, Ld. AR
Section 250Section 36(1)Section 36(1)(vii)Section 36(2)(ii)Section 36(2)(viia)

allowing provision on standard assets of Rs. 41.36 cr. when in fact standard assets are neither bad not doubtful as required by section 36(1) (viia) of the Act." 4 "On the facts and in the circumstances of the case und in law, the Ld. CIT (A) erred in deleting ... allowing provision on standard assets of Rs. 41.36 crs. When in fact standard assets are neither bad nor doubtful as required by section 36(1) (viia) of the Act 8. On the facts and in the circumstances of the case and in law, the Ld. CITIA) erred in deleting

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

In the result, appeal preferred by the assessee is allowed in part

ITA 865/AHD/2016[2011-12]Status: DisposedITAT Ahmedabad07 Aug 2024AY 2011-12

Bench: Ms. Suchitra Kamble, Judical Member & Shri Narendra Prasad Sinhaआयकर अपील सं./I.T.A. No. 865/Ahd/2016 (िनधा"रण वष" िनधा"रण वष" / Assessment Year : 2011-12) िनधा"रण वष" िनधा"रण वष" Intas The Dy. Commissioner Of बनाम बनाम/ बनाम बनाम Biopharmaceuticals Ltd. Income Tax Vs. Plot 423/P/A, Sarkhej Circle-2(1)(1), Ahmedabad Bavla Highway, Moraiya, Sanand, Ahmedabad, Gujarat, 382213 "थायी लेखा सं./जीआइआर सं./Pan/Gir No. : Aabci4722M (Appellant) .. (Respondent) Shri Bandish Soparkar & Shri Parin अपीलाथ" ओर से /Appellant By : Shah, Ars. ""यथ" क" ओर से/Respondent By : Dr. Darsi Suman Ratnam, Cit. Dr & Shri Ashish Rajesh Revar, Sr. Dr Date Of Hearing 24/07/2024 Date Of Pronouncement 07/08/2024 O R D E R Per Shri Narendra Prasad Sinha, Am: This Appeal Is Filed By The Assessee Against The Order Of The Commissioner Of Income-Tax (Appeals)-7, Ahmedabad (In Short ‘The Cit(A)’) Dated 20.01.2016 For The Assessment Year 2011-12. Ita No. 865/Ahd/2016 [Intas Biopharmaceuticals Ltd. Vs. Dcit] A.Y. 2011-12 - 2 –

For Appellant: Shah, ARsFor Respondent: Dr. Darsi Suman Ratnam, CIT. DR
Section 143(3)Section 35Section 40

doubtful debts made in the accounts of the assessee. The deduction in respect of provision for bad and doubtful debt is admissible under Section 36(1)(viia) of the Act, which is applicable to banking companies, financial institutions, non-banking financial company etc. and the said provision is not applicable

M/S. Vaasautomation Private Limited, Kanchipurm vs. ACIT, Coprporate Circle-3(2), Chennai

In the result, all the grounds of appeal raised by the assesse are dismissed

ITA 140/CHNY/2024[2015-16]Status: DisposedITAT Chennai31 Jul 2024AY 2015-16

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.140/Chny/2024 निर्धारण वर्ा /Assessment Years: - 2015-16 M/S.Vaasautomation India Pvt Ltd., The Asst.Commissioner Of Income Plot No.H18 & H19, Sipcot Industrial Tax(Osd), Park, Vallam Vadagal, Echoor Post, Corporate Circle-3(2), Sriperumbudur Taluk, Chennai Kancheepuram Dist, Kanchipuram-631604. [Pan: Aaach2759N] (अपीलार्थी/Assesse) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assesse By : Shri N.Venkatasubramanian, C.A, प्रत्यर्थी की ओर से /Respondent By : Shri P.Sajit Kumar, Jcit सुनवाई की तारीख/Date Of Hearing : 04.07.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024

For Respondent: Shri P.Sajit Kumar, JCIT
Section 143(3)Section 250Section 36(1)(vii)Section 36(1)(viia)Section 36(2)

appreciate that the judgement in the case of Vijaya Bank pertains to the deduction under section 36(1)(vii) and not under section 36(1)(viia). b. The above stand is also confirmed in the Ahmedabad |TAT's decision in the case of Vidras Ceramics (P) Ltd vs DCIT ... claim meaning thereby that all such claims will have to be denied by the AO. It is however pertinent to note that section 36(1)(viia) available on statute w.e.f 01.04.1980 provides that an assesse being a scheduled bank a public / a state financial institution / corporation non-banking financial company

Karnataka Bank Ltd, Mangaluru vs. Assistant Commissioner of Income Tax, Mangaluru

ITA 562/BANG/2024[2020-21]Status: DisposedITAT Bangalore31 Jul 2024AY 2020-21

Bench: Shri Chandra Poojari & Shri Keshav Dubey

Section 115TSection 14ASection 250Section 36(1)(vii)

ITA Nos.555 & 562/Bang/2024 The Karnataka Bank Limited, Mangalore Page 1 of 20 IN THE INCOME TAX APPELLATE TRIBUNAL "C" BENCH

Assistant Commissioner of Income Tax, Circle-1(1), Mangalore vs. The Karnataka Bank Limited, Mangalore

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

ITA 555/BANG/2024[2020-21]Status: DisposedITAT Bangalore31 Jul 2024AY 2020-21

Bench: Shri Chandra Poojari & Shri Keshav Dubeyassessment Year: 2020-21

For Appellant: Sri S. Ananthan & Smt. Lalitha RameswaranFor Respondent: Ms. Neera Malhotra, D.R
Section 115TSection 14ASection 250Section 36(1)(vii)

extracted below:- “Clarification for amount to be eligible for deduction as bad debts in case of banks:- Under the existing provisions of section 36(1)(viia) of the Income-tax Act, in computing the business income of certain banks and financial institutions, deduction is allowable in respect of any provision ... doubtful debts made by such entities subject to certain limits specified therein. The limit specified under section 36(1)(viia)(a) of the Act restrict the claim of deduction for provision for bad and doubtful debts for certain banks (not incorporated outside India) and certain cooperative banks

JCIT (OSD), CC-4(4), Mumbai vs. M/S. Shri Renukamata Multi-State Cooperative Urban Credit Society Ltd., Ahamednagar

ITA 2078/MUM/2023[2018-2019]Status: DisposedITAT Mumbai30 Jul 2024AY 2018-2019

Bench: Shri B.R. Baskaran & Shri Sandeep Singh Karhail

For Appellant: Shri Dharmendra KansaraFor Respondent: Ms. Mahita Nair
Section 142Section 153DSection 250Section 68

details in its books of accounts and such provision includes the amount of provision for bad and doubtful debts, which is allowable under section 36(1)(viia) of the Act. The AO vide order dated 10/05/2021 passed under section 143(3) read with section 153A ... claim of the assessee that the amount includes provisions for doubtful assets, which the assessee is entitled to claim under the provisions of section 36(1)(viia) of the Act is also totally incorrect in law as the said section permits deduction for provision for doubtful debts only in case