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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)

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

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)

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 ... section 36(2)(v) of the Act is as under:- 15. Since the assessee is a financial institution and in terms of section 36(1)(viia) of the Act is allowed to make provisions for bad in doubtful doubts in terms of section 36(1)(viia

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 ... independent of each other. We note that Section 36(1)(vii) of the Act deals with the writing off bad debts whereas the section 36(1)(viia) deals with creation of provisions for bad and doubtful debts based upon the non-performing assets of the bank, which is in accordance

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 ... independent of each other. We note that Section 36(1)(vii) of the Act deals with the writing off bad debts whereas the section 36(1)(viia) deals with creation of provisions for bad and doubtful debts based upon the non-performing assets of the bank, which is in accordance

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 ... independent of each other. We note that Section 36(1)(vii) of the Act deals with the writing off bad debts whereas the section 36(1)(viia) deals with creation of provisions for bad and doubtful debts based upon the non-performing assets of the bank, which is in accordance

JCIT(OSD), Circle -10(1), Delhi vs. M/S Indian Infrastructure Finance Company Limited, Delhi

In the result, the appeal of the Revenue is dismissed

ITA 1251/DEL/2025[2017-18]Status: DisposedITAT Delhi04 Feb 2026AY 2017-18

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Shery Gupta, CAFor Respondent: Ms. Ankush Kalra, Sr. DR
Section 143(3)Section 154Section 36Section 36(1)Section 36(1)(viia)Section 36(1)(viii)Section 861

been computed on the total income before making deduction u/s 36(1)(viii) of the Act, the same being against the provisions of section 36(1)(viia)(c) of the Act which stipulates calculation of total income for the purpose of the said section before making any deduction under ... Allowable deduction u/s 36(1) (viia) (c) of the Act (5% of 43,08,54,038/- income before allowing deduction under section 36(1)(viia) (c) of the Act) i.e. 5% of (C) Accordingly, your honour will acknowledge and appreciate the fact that the deduction claimed by the assesse

ACIT, Circle-2(1)(1), Mumbai vs. M/S Bank of India, Mumbai

ITA 1548/MUM/2023[2018-2019]Status: DisposedITAT Mumbai30 Jan 2026AY 2018-2019

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri C. NareshFor Respondent: Shri Satya Pal Kumar, CIT (DR)
Section 10Section 14ASection 250Section 32Section 90

computing profits and gains from business for the year under consideration. By referring to the provisions for bad and doubtful account maintained under section 36(1)(viia) of the Act, the assessee submitted that the same does not have credit balance as on 01/04/2015, and therefore, no amount is reduced ... claimed as expense in the year of actual write-off of the Bad Debts u/s Section 36(i)(vii). 3. Under Section 36 (1)(viia), bank is allowed 7.5% of the profit and 10% of rural advances as deduction on account for provision for Bad and Doubtful Debt, which

ACIT, Circle-2(1)(1), Mumbai vs. M/S Bank of India, Mumbai

In the result, the appeal by the Revenue for the assessment year 2018-

ITA 1547/MUM/2023[2016-2017]Status: DisposedITAT Mumbai30 Jan 2026AY 2016-2017

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailita No.1452/Mum/2023 Assessment Year : 2016-17 Assessment Year : 2018-19

For Appellant: Shri C. NareshFor Respondent: Shri Satya Pal Kumar, CIT (DR)
Section 10Section 14ASection 250Section 32Section 90

computing profits and gains from business for the year under consideration. By referring to the provisions for bad and doubtful account maintained under section 36(1)(viia) of the Act, the assessee submitted that the same does not have credit balance as on 01/04/2015, and therefore, no amount is reduced ... claimed as expense in the year of actual write-off of the Bad Debts u/s Section 36(i)(vii). 3. Under Section 36 (1)(viia), bank is allowed 7.5% of the profit and 10% of rural advances as deduction on account for provision for Bad and Doubtful Debt, which

Bank of India, Mumbai vs. The National Faceless Assessment Centre, Mumbai

ITA 1452/MUM/2023[2018-19]Status: DisposedITAT Mumbai30 Jan 2026AY 2018-19

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhail

For Appellant: Shri C. NareshFor Respondent: Shri Satya Pal Kumar, CIT (DR)
Section 10Section 14ASection 250Section 32Section 90

computing profits and gains from business for the year under consideration. By referring to the provisions for bad and doubtful account maintained under section 36(1)(viia) of the Act, the assessee submitted that the same does not have credit balance as on 01/04/2015, and therefore, no amount is reduced ... claimed as expense in the year of actual write-off of the Bad Debts u/s Section 36(i)(vii). 3. Under Section 36 (1)(viia), bank is allowed 7.5% of the profit and 10% of rural advances as deduction on account for provision for Bad and Doubtful Debt, which

Bank of India, Mumbai vs. ACIT-2(1)(2), Mumbai

In the result, the appeal by the Revenue for the assessment year 2018-

ITA 1451/MUM/2023[2016-17]Status: DisposedITAT Mumbai30 Jan 2026AY 2016-17

Bench: Shri Vikram Singh Yadavshri Sandeep Singh Karhailita No.1452/Mum/2023 Assessment Year : 2016-17 Assessment Year : 2018-19

For Appellant: Shri C. NareshFor Respondent: Shri Satya Pal Kumar, CIT (DR)
Section 10Section 14ASection 250Section 32Section 90

computing profits and gains from business for the year under consideration. By referring to the provisions for bad and doubtful account maintained under section 36(1)(viia) of the Act, the assessee submitted that the same does not have credit balance as on 01/04/2015, and therefore, no amount is reduced ... claimed as expense in the year of actual write-off of the Bad Debts u/s Section 36(i)(vii). 3. Under Section 36 (1)(viia), bank is allowed 7.5% of the profit and 10% of rural advances as deduction on account for provision for Bad and Doubtful Debt, which

Bajaj Finance Limited, Pune vs. Principal Commissioner of Income Tax-3, Pune

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

ITA 565/PUN/2024[2019-20]Status: DisposedITAT Pune29 Jan 2026AY 2019-20

Bench: Shri R. K. Panda & Shri Vinay Bhamoreassessment Year : 2019-20 Bajaj Finance Limited Pcit-3, Pune 3Rd Floor, Panchshil Tech Park, Vs. Viman Nagar, Pune – 411014 Pan: Aabcb1518L (Appellant) (Respondent) Assessee By : Shri Percy Pardiwalla Department By : Shri Amol Khairnar, Cit-Dr Date Of Hearing : 06-01-2026 Date Of Pronouncement : 29-01-2026

For Appellant: Shri Percy PardiwallaFor Respondent: Shri Amol Khairnar, CIT-DR
Section 143(3)Section 263Section 41Section 80J

during the course of original assessment proceedings had made necessary enquiry and verification, before allowing the claim made by the Appellant under section 36(1)(viia) of the Act. 1.3. The learned PCIT ought to have appreciated that the proceedings under section 263 of the Act cannot be initiated ... issues based on mere difference in opinion from the position adopted by the learned AO. 2. Ground 2. Challenging the deduction claimed under section 36(1)(viia) of the Act on standard assets: 17 2.1 The learned PCIT erred in holding that deduction under section 36(1)(viia

The Modas Nagarik Sahakari Bank Ltd., Arvalli vs. The ACIT, Circle-2(1)(1), Ahmedabad

Appeal of the assessee is treated as allowed for statistical purposes

ITA 1573/AHD/2025[2018-19]Status: DisposedITAT Ahmedabad28 Jan 2026AY 2018-19

Bench: Shri Sanjay Garg & Annapurna Guptaआयकर अपील सं /Ita No.1573/Ahd/2025 िनधा"रण वष" /Assessment Year : 2018-19 The Modasa Nagarik Sahakari The Acit बनाम/ Bank Ltd. Circle-2(1)(1) V/S. Sutharwada, Nr.Nagar Palika Anandnagar-Prahladnagar Po: Modasa – 383 315 Ahmedabad-380 015 Dist. Aravalli (S.K.) "थायी लेखा सं./Pan: Aaaat 0525 G (अपीलाथ(/ Appellant) ()* यथ(/ Respondent) Assessee By : Shri Dhinal Shah, Ar Revenue By : Shri Rohit Aasudani, Sr.Dr सुनवाई की तारीख/Date Of Hearing : 21/01/2026 घोषणा की तारीख /Date Of Pronouncement: 28/01/2026 आदेश/O R D E R Per Sanjay Garg:

For Appellant: Shri Dhinal Shah, ARFor Respondent: Shri Rohit Aasudani, Sr.DR
Section 250Section 36(1)(viia)

directed to verify the claim of expenditure and if the assessee is entitled to the same under the provisions of section 36(1)(viia) of the Act, the same may be allowed to the assessee. 8. Ground No.3 is general in nature. 9. In view of the above discussion, appeal

Deputy Commissioner Income Tax Non Corp Circle II Madurai, Madurai vs. Virudhunagar District Central Co Op Bank Limited, Virudhunagar

ITA 2700/CHNY/2025[2015-16]Status: DisposedITAT Chennai28 Jan 2026AY 2015-16
Section 14ASection 36(1)(viia)

allowed independently based on the statutory percentages, irrespective of the quantum of provision made ? 4. The learned counsel for the assessee submitted that section 36(1)(viia) provides for a statutory deduction, the quantum of which is determined by the prescribed percentages of total income and aggregate average rural advances ... provisioning norms regulate financial reporting, whereas tax deductions are governed exclusively by the Income-tax Act. The assessee traced the legislative history of section 36(1)(viia) through successive Finance Acts to demonstrate the consistent intent of Parliament to incentivise rural banking.Reliance was placed on decisions such as Syndicate Bank

Deputy Commissioner of Income Tax Non Corp Circle II Madurai, Madurai vs. Virudhunagar District Central Co Op Bank Limited, Virudhunagar

ITA 2699/CHNY/2025[2013-14]Status: DisposedITAT Chennai28 Jan 2026AY 2013-14

Bench: Ms. Padmavathy S & Shri Manu Kumar Giriआयकर अपीलसं/.Ita Nos.: 2699/Chny/2025 &2700/Chny/2025 By Revenue C.O.No.92/Chny/2025 (In Ita No.: 2699/Chny/2025)& C.O.No.93/Chny/2025 (In Ita No.: 2700/Chny/2025) By Assessee निर्धारणवर्ष / Assessment Years: 2013-14 & 2015-16 Dcit, Non Corp Circle Ii, Madurai, V.P. Rathinasamy Nadar Road, Bb Kulam Madurai-625002, Madurai, Tamil Nadu (अपीलार्थी/Assessee) V. Virudhunagar District Central Co-Operative Bank Limited 104/1, Madurai Road, Kamaraj Nagar, S.O. Virudhunagar,Virudhunagar- 626001. Tamil Nadu [Pan:Aaaav 0147 N] (प्रत्यर्थी/Respondent) अपीलार्थीकीओरसे//Assessee By Mr. R. Prasanna Venkatesan, F.C.A. प्रत्यर्थीकी ओरसे Respondent/Revenue By Mr. Shiva Srinivas, Cit सुनवाईकीतारीख/Date Of Hearing 20.01.2026 घोषणाकीतारीख /Date Of Pronouncement 28.01.2026 :-2-:

Section 14ASection 36(1)(viia)

allowed independently based on the statutory percentages, irrespective of the quantum of provision made ? 4. The learned counsel for the assessee submitted that section 36(1)(viia) provides for a statutory deduction, the quantum of which is determined by the prescribed percentages of total income and aggregate average rural advances ... Chny 2025 DCIT NON CIRCLE II MADURAI VS VIRUDHUNAGAR DISTRICT CENTRAL CO OP BANK LIMITED Act. The assessee traced the legislative history of section 36(1)(viia) through successive Finance Acts to demonstrate the consistent intent of Parliament to incentivise rural banking.Reliance was placed on decisions such as Syndicate Bank

Vimal Alloys Private Limited, Mandi Gobindgarh, Punjab vs. Jao the Deputy Commissioner of Income Tax Circle, Patiala, Punjab

ITA 890/CHANDI/2025[2016-2017]Status: DisposedITAT Chandigarh21 Jan 2026AY 2016-2017

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Sudhir Sehgal, Advocate and Shri Vipen Sethi, AdvocateFor Respondent: Dr. Ranjit Kaur, Addl. CIT, Sr. DR
Section 143(1)Section 147Section 148Section 151Section 69A

Para 3] [In favour of assessee] [2023] 155 taxmann.com 290 (SC) SUPREME COURT OF INDIA Commissioner of Income-tax v. Canara Bank* Section 36(1)(viia), read with section 148, of the Income-tax Act, 1961 - Bad debts, in case of banks (Reassessment) - Assessment years ... that there was failure on part of assessee to disclose fully and truly all material facts in respect of claim of deduction under section 36(1)(viia), Tribunal rightly held that reopening assessment initiated beyond four years was bad in law - Whether SLP filed by revenue against said impugned order

ACIT, Circle-10(1), New Delhi vs. Index Securities & Research Pvt Ltd, New Delhi

In the result, the appeal filed by the Department of Revenue is dismissed

ITA 2181/DEL/2022[2016-17]Status: DisposedITAT Delhi16 Jan 2026AY 2016-17

Bench: Shri S Rifaur Rahman & Shri Vimal Kumar

Section 142(1)Section 143(2)Section 250Section 68

deduction under section 36(1)(vii). 6.4 Inapplicability of Section 36(1)(vila)(d): The Assessee has not claimed the benefit under section 36(1)(viia)(d), nor is it eligible, as it was inserted via the Finance Act, 2016 and became operative from 01.04.2017. Hence, the general provision under

The Farrukhabad District Co- Operative Bank Ltd, Fatehagarh vs. DCIT, Circle-2, (1), Farrukhabad

In the result, ground No. 6 raised by the assessee is

ITA 75/AGR/2016[2012-13]Status: DisposedITAT Agra15 Jan 2026AY 2012-13

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2008-09

Section 120(4)(b)Section 143(1)Section 143(2)Section 2Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL, AGRA BENCH, AGRA BEFORE : SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI SUNIL KUMAR

The Farrukhabad District Cooperative Bank, Farrukhabad vs. Addl. C.I.T., Range-2, Farrukhabad

In the result, ground No. 6 raised by the assessee is

ITA 138/AGR/2014[2008-09]Status: DisposedITAT Agra15 Jan 2026AY 2008-09

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2008-09

Section 120(4)(b)Section 143(1)Section 143(2)Section 2Section 250

IN THE INCOME TAX APPELLATE TRIBUNAL, AGRA BENCH, AGRA BEFORE : SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI SUNIL KUMAR

Shriram Finance Ltd., Chennai vs. PCIT, Chennai

ITA 2043/CHNY/2025[2022-23]Status: DisposedITAT Chennai08 Jan 2026AY 2022-23

Bench: Shri M. Balaganesh & Shri S.S. Viswanethra Raviआयकर अपील सं./I.T.A. No.2043/Chny/2025 िनधा"रण वष"/Assessment Year: 2022-23 Shriram Finance Limited, Vs. The Principal Commissioner Of [Since Shriram City Union Finance Income Tax – 3, Limited Amalgamated With Shriram Chennai. Transport Finance Co. Limited & Presently Known As Shriram Finance Limited], Sri Towers, Plot No. 14A, South Phase, Industrial Estate, Guindy, Chennai 600 032. [Pan:Aaacs7018R] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri R. Sivaraman, Advocate ""थ" की ओर से/Respondent By : Shri C.N. Bipin, Cit सुनवाई की तारीख/ Date Of Hearing : 15.10.2025 घोषणा की तारीख /Date Of Pronouncement : 08.01.2026 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 28.05.2025 Passed By The Ld. Principal Commissioner Of Income Tax – 3, Chennai For The Assessment Year 2022-23 Under Section 263 Of The Income Tax Act, 1961 [“Act” In Short].

For Appellant: Shri R. Sivaraman, AdvocateFor Respondent: Shri C.N. Bipin, CIT
Section 143(3)Section 234DSection 263Section 36(1)(vii)Section 36(1)(viia)Section 4

income for the F.Y. 2020-21 relevant to the AY 2021-22, an amount of ₹.99,78,811/- was claimed as deduction under section 36(1)(viia)(d) of the Act relating to provision created during the year for bad debts. Since for F.Y. 2021-22, the amount

ACIT, Circle-2(1)(1), Mumbai vs. M/S Bank of India, Mumbai

In the result, appeal of the revenue is dismissed

ITA 1549/MUM/2023[2013-2014]Status: DisposedITAT Mumbai23 Dec 2025AY 2013-2014

Bench: MS. SUCHITRA RAGHUNATH KAMBLE (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

For Appellant: Shri P. J. Pardiwala, Sr. Advocate and Shri C. Naresh, CAFor Respondent: Shri Satya Pal Kumar, CIT DR
Section 10Section 115JSection 143(3)Section 14ASection 90

viia) after set-off of these b/f losses. Aggrieved, assessee went in appeal before the ld. CIT(A). Ld. CIT(A) referred to section 36(1)(viia) as extracted below: “….. (viia) in respect of any provision for bad and doubtful debts made by- (a) a scheduled bank not being ... bold] 23.2. In view of the above decision, ld. CIT(A) held that the total income for the purpose of section 36(1)(viia) will be determined after set-off of brought forwarded losses. Accordingly, he upheld the working of net AY 2013-14 profit after set-off of brought