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“Section 36(1)(viia)(a)”

Section References (mined)Section 36Section 36(1)(viia)(a)38 judgments

SHRI RAJKOT DISTRICT CO-OPERATIVE BANK LTD.,RAJKOT vs. THE DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE - 1(2), RAJKOT , RAJKOT

The appeal is dismissed

ITA 196/RJT/2024[2011-12]Status: DisposedITAT Rajkot04 Nov 2025AY 2011-12

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita No.196/Rjt/2024 ("नधा"रण वष" / Assessment Year: (2011-12) Shri Rajkot District Co-Operative Vs. The Deputy Commissioner Of Bank Ltd., Income-Tax, Circle-1(1), Jilla Bank Bhavan, Kasturba Road, Aayakar Bhavan, Race Course Ring Opp. Chaudhary High School, Road, Rajkot-360001 Rajkot-360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Afups2094H (Appellant) (Respondent) Appellant By : Shri D.M. Rindani, Ld. Ar Respondent By : Smt. Pallavi, Ld. Cit(Dr) : 06/08/2025 Date Of Hearing Date Of Pronouncement : 04/11/2025 आदेश / O R D E R Per, Dinesh Mohan Sinha, Jm: Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year (Ay)-2018-19, Is Directed Against The Order Passed By The Commissioner Of Income Tax Office [(In Short “Ld.Cit(A)”] Vide Order Dated 29.12.2023, Which In Turn Assessment Order Passed By Income Tax Department / Assessing Officer Under Section 144C(1) Of The Income Tax Act, 1961 (In Short “The Act”), Vide Order Dated 30.03.2023 2. Grounds Of Appeal Raised By The Assessee, Are As Follows:

For Appellant: Shri D.M. Rindani, Ld. ARFor Respondent: Smt. Pallavi, Ld. CIT(DR)
Section 143(3)Section 144C(1)Section 263Section 271(1)(c)Section 36(1)Section 36(1)(viia)

purposes of computing the taxable income of the assessee in the earlier years as and when created, as per the provisions of section 36(1)(viia) of the Act. The details of the said claim have been brought out by the Ld.PCIT in his show cause notice reproduced above. Page ... Rajkot Dist. Co-op. Bank Ltd. 15. The provisions of section 36(1)(viia) of the Act are very clear, allowing claim of deduction on account of provision for bad and doubtful debts, to the extent the provisions aremade. This is the exact word (made) used in the section alongwith

ACIT (LTU)-1, MUMBAI vs. UNION BANK OF INDIA, MUMBAI

In the result, appeal of the assessee is allowed

ITA 882/MUM/2020[2015-16]Status: DisposedITAT Mumbai11 Aug 2025AY 2015-16
For Appellant: Shri C Naresh, A/RFor Respondent: Shri Vivek Perampurna, CIT D/R
Section 115JSection 36(1)(vii)Section 36(1)(viia)

1)(vii) w.e.f 01/04/2014.\n5. Drawing support from the provisions of Section 36(1)(vii) read\nwith its proviso along with provision of Section 36(1)(viia) of the Act and\nCBDT Circular No. 464 dated 18/07/1986 along with clarificatory\namendment made to Section 36(1)(vii) vide Finance ... extracted\nbelow:-\n\"Clarification for amount to be eligible for deduction as bad debts in\ncase of banks:-\nUnder the existing provisions of section 36(1)(viia) of the Income-tax Act, in\ncomputing the business income of certain banks and financial institutions,\ndeduction is allowable in respect

DY..C.I.T., BANGALORE vs. M/S STATE BANK OF MYSORE, BANGALORE

In the result, appeal of the revenue is dismissed

ITA 681/BANG/2015[2005-06]Status: DisposedITAT Mumbai29 Jan 2025AY 2005-06

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

For Appellant: Shri Ninad Patade, A/RFor Respondent: Shri P.C. Chhotaray, Spl. Counsel, D/R
Section 143(3)Section 154Section 2(45)Section 36(1)(viia)Section 5

deduction u/s 36(1)(viia) of the Act and excluding income under the head capital gains. Attention was drawn to the provisions of Section 36(1)(viia) of the Act which provides for provision for bad and doubtful debts in the case of a schedule bank not being a bank ... CBDT in the Instruction No. 17/2008, dated 26/11/2008. The relevant clause of the Instruction reads as under:- I.T.A. No. 681/Bang/2015 4 “(iii) Section 36(1)(viia)(a) of the Act provides that in respect of any provisions for bad and doubtful debts of the type referred to in that

WARANGAL URBAN CO-OPERATIVE BANK LIMITED,HYDERABAD vs. ACIT., CIRCLE-1, HYDERABAD

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

ITA 693/HYD/2024[2015-16]Status: DisposedITAT Hyderabad29 Nov 2024AY 2015-16

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdia

For Appellant: Shri P. Murali Mohan Rao, C.AFor Respondent: Shri Waseem UR Rehman, SR-DR
Section 143(2)Section 143(3)Section 36(1)(viia)

submitted that the assessee being a banking company is eligible to claim the provisions created on account of doubtful debts in terms of section 36(1)(viia)(a) of the Act upto the limit prescribed thereon. Therefore the Ld. AR prayed before the bench to delete the disallowances made ... deduction u/s.36(1)(viia)(a) of the Act. We have gone through both the decisions of ITAT (supra) and provisions contained in section 36(1)(viia)(a) of the Act and found that, the assessee is eligible for deduction on account of provision created for doubtful debts upto the limit

THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 2(1), MANGALORE vs. KARNATAKA BANK LIMITED., MANGALORE

In the result, the appeal of the assessee is partly allowed for statistical purposes and the revenue’s appeal is dismissed

ITA 161/PAN/2019[2015-16]Status: DisposedITAT Bangalore30 Sept 2024AY 2015-16

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K., Judciial Member Assessment Year : 2015-16

For Appellant: Shri Ananthan S. & Smt. Lalitha Rameswaran, CAsFor Respondent: Shri D.K. Mishra, CIT(DR)(ITAT), Bengaluru
Section 115JSection 14ASection 234BSection 36(1)(vii)Section 36(1)(viia)Section 40Section 41(4)

1)(vii) and 36(1)(viia). While 36(1)(vii) speaks of actual write off of bad debts in the books of account, section 36(1)(viia) even allows provision made towards bad and doubtful debts in respect of rural advances to the extent of provision made in the books ... clause (viia) of section 36(1). Proviso to section 36(1)(vii) operates only in a case where deduction is also claimed under section 36(1)(viia). In other words, proviso to section 36(1)(vii) applies to write off of bad debts relating to rural advances to the extent

M/S. KARNATAKA BANK LIMITED,MANGALURU vs. THE DEPUTY COMMISSIONER OF INCOME TAX. CIRCLE- 2(1), MANGALURU

In the result, the appeal of the assessee is partly allowed for statistical purposes and the revenue’s appeal is dismissed

ITA 1107/BANG/2019[2015-16]Status: DisposedITAT Bangalore30 Sept 2024AY 2015-16

Bench: Shri Laxmi Prasad Sahu & Shri Soundararajan K., Judciial Member Assessment Year : 2015-16

For Appellant: Shri Ananthan S. & Smt. Lalitha Rameswaran, CAsFor Respondent: Shri D.K. Mishra, CIT(DR)(ITAT), Bengaluru
Section 115JSection 14ASection 234BSection 36(1)(vii)Section 36(1)(viia)Section 40Section 41(4)

1)(vii) and 36(1)(viia). While 36(1)(vii) speaks of actual write off of bad debts in the books of account, section 36(1)(viia) even allows provision made towards bad and doubtful debts in respect of rural advances to the extent of provision made in the books ... clause (viia) of section 36(1). Proviso to section 36(1)(vii) operates only in a case where deduction is also claimed under section 36(1)(viia). In other words, proviso to section 36(1)(vii) applies to write off of bad debts relating to rural advances to the extent

JCIT (OSD) CIRCLE-2, TRICHY vs. THE KARUR VYSYA BANK LTD., KARUR

In the result, appeal filed by the Revenue for assessment year

ITA 635/CHNY/2020[2017-18]Status: DisposedITAT Chennai20 Sept 2024AY 2017-18

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. R. Raghunatha, Hon’Bleआयकर अपील सं./Ita No.: 620/Chny/2020 िनधा"रण वष" / Assessment Year: 2017-18 Deputy Commissioner Of Income M/S. Karur Vysya Bank, V. Tax, Finance &Control Dept., Circle -2(1), Erode Road, Trichy. Karur – 639 002. [Pan: Aaact-3373-J] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita No.: 635/Chny/2020 िनधा"रण वष" / Assessment Year: 2017-18 M/S. Karur Vysya Bank, The Joint Commissioner Of V. Finance &Control Dept., Income Tax, Erode Road, Circle -2, Karur – 639 002. No.44, Williams Road, [Pan: Aaact-3373-J] Contanment, Trichy – 620 001. (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee By : Shri. Ananthan, Ca & Smt. R. Lalitha, Ca Department By : Shri. Nilay Baran Som, Cit सुनवाई क" तारीख/Date Of Hearing : 05.08.2024 घोषणा क" तारीख/Date Of Pronouncement : 20.09.2024 आदेश /O R D E R Per S. R. Raghunatha:

For Appellant: Shri. Ananthan, CA & Smt. R. Lalitha, CAFor Respondent: Shri. Nilay Baran Som, CIT
Section 145Section 36(1)Section 36(1)(vii)Section 36(1)(viia)Section 36(2)(v)

including addition towards stale :-7-: ITA. Nos: 620 & 635/Chny/2020 drafts account, disallowance of exgratia, disallowance u/s.14A, income received in advance and disallowance under Section 36(1)(viia). However, sustained additions made towards disallowance of bad debts written off and depreciation on investments. The ld. CIT(A) had also enhanced ... pertains to non rural branches. It adjusted Rs.37,52,341/- which pertains to rural branches against the provision account under Section 36(1)(viia). The Assessing Officer, however disallowed Rs.73,48,83,942/- by holding that the non – rural debts should also be adjusted against the provision account

M/S. KARUR VYSYA BANK,,KARUR vs. DCIT, CIRCLE - 2 (1),, TRICHY

ITA 620/CHNY/2020[2017-18]Status: DisposedITAT Chennai20 Sept 2024AY 2017-18
Section 145Section 36(1)(vii)Section 36(1)(viia)Section 36(2)(v)

pertains to non rural branches. It adjusted\nRs.37,52,341/- which pertains to rural branches against the\nprovision account under Section 36(1)(viia). The Assessing Officer,\nhowever disallowed Rs.73,48,83,942/- by holding that the non\nrural debts should also be adjusted against the provision account\nunder Section ... dealt in detail in\nlight of provisions of section 36(1)(vii) of the Act and explanation\nprovided thereunder and also provisions of section 36(1)(viia) r.w.s.\n36(2)(v) of the Act. The Tribunal had also discussed the issue in\nlight of explanation (2) inserted by Finance

KARNATAKA BANK LTD,MANGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX , MANGALURU

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

ITA 562/BANG/2024[2020-21]Status: DisposedITAT Bangalore31 Jul 2024AY 2020-21
Section 115TSection 14ASection 250Section 36(1)(vii)

extracted below:-\n\"Clarification for amount to be eligible for deduction as bad debts in case\nof banks:-\nUnder the existing provisions of section 36(1)(viia) of the Income-tax Act,\nin computing the business income of certain banks and financial\ninstitutions, deduction is allowable in respect ... provision for bad\nand doubtful debts made by such entities subject to certain limits\nspecified therein. The limit specified under section 36(1)(viia)(a) of the\nAct restrict the claim of deduction for provision for bad and doubtful\ndebts for certain banks (not incorporated outside India) and certain\ncooperative

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

THE ANDHRA PRADESH STATE CO-OPERATIVE BANK LTD,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

ITA 464/HYD/2023[2010-11]Status: DisposedITAT Hyderabad29 Jul 2024AY 2010-11

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri M.V.Anil Kumar, AdvocateFor Respondent: : Ms. K. Haritha, CIT-DR
Section 36Section 36(1)(vii)Section 36(1)(viia)Section 37

applicable only from 1-4-2007, it is an undisputed fact that no provision for bad debts or provision as per section 36(1)(viia) was made in the books and allowed by the Assessing Officer in any of the earlier years, ought to have allowed the bad debts written ... PACS, followed by DCCBS, are debts written off and eligible for deduction under section 36(1)(vii) in absence of any provision under section 36(1)(viia) r.w.s 36(2)(v) of the Income Tax Act, 1961. 3. Your Appellant submits that provision of section 36(1)(vii) and 36

THE ANDHRA PRADESH STATE CO-OPERATIVE BANK LTD,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

ITA 463/HYD/2023[2014-15]Status: DisposedITAT Hyderabad29 Jul 2024AY 2014-15

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri M.V.Anil Kumar, AdvocateFor Respondent: : Ms. K. Haritha, CIT-DR
Section 36Section 36(1)(vii)Section 36(1)(viia)Section 37

applicable only from 1-4-2007, it is an undisputed fact that no provision for bad debts or provision as per section 36(1)(viia) was made in the books and allowed by the Assessing Officer in any of the earlier years, ought to have allowed the bad debts written ... PACS, followed by DCCBS, are debts written off and eligible for deduction under section 36(1)(vii) in absence of any provision under section 36(1)(viia) r.w.s 36(2)(v) of the Income Tax Act, 1961. 3. Your Appellant submits that provision of section 36(1)(vii) and 36

THE ANDHRA PRADESH STATE CO-OPERATIVE BANK LTD,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

ITA 462/HYD/2023[2013-14]Status: DisposedITAT Hyderabad29 Jul 2024AY 2013-14

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri M.V.Anil Kumar, AdvocateFor Respondent: : Ms. K. Haritha, CIT-DR
Section 36Section 36(1)(vii)Section 36(1)(viia)Section 37

applicable only from 1-4-2007, it is an undisputed fact that no provision for bad debts or provision as per section 36(1)(viia) was made in the books and allowed by the Assessing Officer in any of the earlier years, ought to have allowed the bad debts written ... PACS, followed by DCCBS, are debts written off and eligible for deduction under section 36(1)(vii) in absence of any provision under section 36(1)(viia) r.w.s 36(2)(v) of the Income Tax Act, 1961. 3. Your Appellant submits that provision of section 36(1)(vii) and 36

THE ANDHRA PRADESH STATE CO-OPERATIVE BANK LTD,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-5(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

ITA 461/HYD/2023[2012-13]Status: DisposedITAT Hyderabad29 Jul 2024AY 2012-13

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri M.V.Anil Kumar, AdvocateFor Respondent: : Ms. K. Haritha, CIT-DR
Section 36Section 36(1)(vii)Section 36(1)(viia)Section 37

applicable only from 1-4-2007, it is an undisputed fact that no provision for bad debts or provision as per section 36(1)(viia) was made in the books and allowed by the Assessing Officer in any of the earlier years, ought to have allowed the bad debts written ... PACS, followed by DCCBS, are debts written off and eligible for deduction under section 36(1)(vii) in absence of any provision under section 36(1)(viia) r.w.s 36(2)(v) of the Income Tax Act, 1961. 3. Your Appellant submits that provision of section 36(1)(vii) and 36

THE ANDHRA PRADESH STATE CO-OPERATIVE BANK LTD,VIJAYAWADA vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

ITA 460/HYD/2023[2011-12]Status: DisposedITAT Hyderabad29 Jul 2024AY 2011-12

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri M.V.Anil Kumar, AdvocateFor Respondent: : Ms. K. Haritha, CIT-DR
Section 36Section 36(1)(vii)Section 36(1)(viia)Section 37

applicable only from 1-4-2007, it is an undisputed fact that no provision for bad debts or provision as per section 36(1)(viia) was made in the books and allowed by the Assessing Officer in any of the earlier years, ought to have allowed the bad debts written ... PACS, followed by DCCBS, are debts written off and eligible for deduction under section 36(1)(vii) in absence of any provision under section 36(1)(viia) r.w.s 36(2)(v) of the Income Tax Act, 1961. 3. Your Appellant submits that provision of section 36(1)(vii) and 36

THE ANDHRA PRADESH STATE CO OPERATIVE BANK LIMITED,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-4(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

ITA 241/HYD/2018[2009-10]Status: DisposedITAT Hyderabad29 Jul 2024AY 2009-10

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri M.V.Anil Kumar, AdvocateFor Respondent: : Ms. K. Haritha, CIT-DR
Section 36Section 36(1)(vii)Section 36(1)(viia)Section 37

applicable only from 1-4-2007, it is an undisputed fact that no provision for bad debts or provision as per section 36(1)(viia) was made in the books and allowed by the Assessing Officer in any of the earlier years, ought to have allowed the bad debts written ... PACS, followed by DCCBS, are debts written off and eligible for deduction under section 36(1)(vii) in absence of any provision under section 36(1)(viia) r.w.s 36(2)(v) of the Income Tax Act, 1961. 3. Your Appellant submits that provision of section 36(1)(vii) and 36

THE ANDHRA PRADESH STATE COOPERATIVE BANK LIMITED,HYDERABAD vs. ASST.COMMISSIONER OF INCOME TAX, CIRCLE-5(1), HYDERABAD

In the result, the S.As. filed by the assessee are dismissed

ITA 1796/HYD/2017[2008-09]Status: DisposedITAT Hyderabad29 Jul 2024AY 2008-09

Bench: Shri Laliet Kumar & Shri Madhusudan Sawdia

For Appellant: Shri M.V.Anil Kumar, AdvocateFor Respondent: : Ms. K. Haritha, CIT-DR
Section 36Section 36(1)(vii)Section 36(1)(viia)Section 37

applicable only from 1-4-2007, it is an undisputed fact that no provision for bad debts or provision as per section 36(1)(viia) was made in the books and allowed by the Assessing Officer in any of the earlier years, ought to have allowed the bad debts written ... PACS, followed by DCCBS, are debts written off and eligible for deduction under section 36(1)(vii) in absence of any provision under section 36(1)(viia) r.w.s 36(2)(v) of the Income Tax Act, 1961. 3. Your Appellant submits that provision of section 36(1)(vii) and 36

KARUR VYSYA BANK LTD.,KARUR vs. DCIT CIRCLE 2(1), TRICHY

ITA 678/CHNY/2019[2015-16]Status: DisposedITAT Chennai09 Apr 2024AY 2015-16

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकरअपीलसं./Ita Nos.: 677 & 678/Chny/2019 िनधा"रणवष" / Assessment Years: 2014-15 & 2015-16 M/S. Karur Vysya Bank Ltd, Deputy Commissioner Of Central Office, V. Income Tax, Erode Road, Circle -2(1), Karur – 639 002. Trichy. [Pan: Aaact-3373-J] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकरअपीलसं./Ita Nos.: 1343 & 1321/Chny/2019 िनधा"रणवष" / Assessment Years: 2014-15 & 2015-16 Deputy Commissioner Of M/S. Karur Vysya Bank Ltd, Income Tax, V. Central Office, Circle -2(1), Erode Road, Trichy. Karur – 639 002. [Pan: Aaact-3373-J (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee By : Shri. Anandhan, Ca & Smt. Lalitha, Ca Revenue By : Shri. Nilay Baran Som, Cit सुनवाई क" तारीख/Date Of Hearing : 13.03.2024 घोषणा क" तारीख/Date Of Pronouncement : 09.04.2024 आदेश /O R D E R

For Appellant: Shri. Anandhan, CA and Smt. Lalitha, CAFor Respondent: Shri. Nilay Baran Som, CIT
Section 36(1)(viii)Section 41(1)Section 43B

moved an enhancement petition contending that bad debts written off should be adjusted against the provision for bad & doubtful debts account made under section 36(1)(viia) without any distinction between rural and other advances and only excess over the credit balance in the account can be claimed as deduction ... dealt in detail in light of provisions of section 36(1)(vii) of the Act and explanation provided thereunder and also provisions of section 36(1)(viia) r.w.s. 36(2)(v) of the Act. The Tribunal had also discussed the issue in light of explanation (2) inserted by Finance

KARUR VYSYA BANK LTD.,KARUR vs. DCIT CIRCLE 2(1), TRICHY

ITA 677/CHNY/2019[2014-15]Status: DisposedITAT Chennai09 Apr 2024AY 2014-15

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकरअपीलसं./Ita Nos.: 677 & 678/Chny/2019 िनधा"रणवष" / Assessment Years: 2014-15 & 2015-16 M/S. Karur Vysya Bank Ltd, Deputy Commissioner Of Central Office, V. Income Tax, Erode Road, Circle -2(1), Karur – 639 002. Trichy. [Pan: Aaact-3373-J] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकरअपीलसं./Ita Nos.: 1343 & 1321/Chny/2019 िनधा"रणवष" / Assessment Years: 2014-15 & 2015-16 Deputy Commissioner Of M/S. Karur Vysya Bank Ltd, Income Tax, V. Central Office, Circle -2(1), Erode Road, Trichy. Karur – 639 002. [Pan: Aaact-3373-J (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee By : Shri. Anandhan, Ca & Smt. Lalitha, Ca Revenue By : Shri. Nilay Baran Som, Cit सुनवाई क" तारीख/Date Of Hearing : 13.03.2024 घोषणा क" तारीख/Date Of Pronouncement : 09.04.2024 आदेश /O R D E R

For Appellant: Shri. Anandhan, CA and Smt. Lalitha, CAFor Respondent: Shri. Nilay Baran Som, CIT
Section 36(1)(viii)Section 41(1)Section 43B

moved an enhancement petition contending that bad debts written off should be adjusted against the provision for bad & doubtful debts account made under section 36(1)(viia) without any distinction between rural and other advances and only excess over the credit balance in the account can be claimed as deduction ... dealt in detail in light of provisions of section 36(1)(vii) of the Act and explanation provided thereunder and also provisions of section 36(1)(viia) r.w.s. 36(2)(v) of the Act. The Tribunal had also discussed the issue in light of explanation (2) inserted by Finance

DCIT CIRCLE 2(1), TRICHY vs. THE KARUR VYSYA BANK LTD., KARUR

ITA 1343/CHNY/2019[2014-15]Status: DisposedITAT Chennai09 Apr 2024AY 2014-15

Bench: Shri V. Durga Rao, Hon’Ble & Shri Manjunatha. G, Hon’Bleआयकरअपीलसं./Ita Nos.: 677 & 678/Chny/2019 िनधा"रणवष" / Assessment Years: 2014-15 & 2015-16 M/S. Karur Vysya Bank Ltd, Deputy Commissioner Of Central Office, V. Income Tax, Erode Road, Circle -2(1), Karur – 639 002. Trichy. [Pan: Aaact-3373-J] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकरअपीलसं./Ita Nos.: 1343 & 1321/Chny/2019 िनधा"रणवष" / Assessment Years: 2014-15 & 2015-16 Deputy Commissioner Of M/S. Karur Vysya Bank Ltd, Income Tax, V. Central Office, Circle -2(1), Erode Road, Trichy. Karur – 639 002. [Pan: Aaact-3373-J (अपीलाथ"/Appellant) (""यथ"/Respondent) Assessee By : Shri. Anandhan, Ca & Smt. Lalitha, Ca Revenue By : Shri. Nilay Baran Som, Cit सुनवाई क" तारीख/Date Of Hearing : 13.03.2024 घोषणा क" तारीख/Date Of Pronouncement : 09.04.2024 आदेश /O R D E R

For Appellant: Shri. Anandhan, CA and Smt. Lalitha, CAFor Respondent: Shri. Nilay Baran Som, CIT
Section 36(1)(viii)Section 41(1)Section 43B

moved an enhancement petition contending that bad debts written off should be adjusted against the provision for bad & doubtful debts account made under section 36(1)(viia) without any distinction between rural and other advances and only excess over the credit balance in the account can be claimed as deduction ... dealt in detail in light of provisions of section 36(1)(vii) of the Act and explanation provided thereunder and also provisions of section 36(1)(viia) r.w.s. 36(2)(v) of the Act. The Tribunal had also discussed the issue in light of explanation (2) inserted by Finance

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