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“Section 36(1)(vii)”

Section References (mined)Section 36Section 36(1)(vii)853 judgments

The decision most relied on for Section 36(1)(vii) is TRF Ltd. v. CIT (323 ITR 397), cited in 714 judgments on BharatTax.

Leading authorities on Section 36(1)(vii)

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.

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.

Judgments citing Section 36(1)(vii)

Elcome Technologies Private Limited, Mumbai vs. Dy. Commissioner of Income Tax, Mumbai

Appeal of the assessee is partly allowed

ITA 6188/MUM/2025[2018-19]Status: DisposedITAT Mumbai09 Dec 2025AY 2018-19

Bench: Shri Saktijit Dey, Vp & Ms Padmavathy S, Am

For Respondent: Shri Himanshu Joshi, Sr.-DR
Section 250Section 250(4)Section 37Section 41(1)

case of Desouza Hotels Ltd (supra) where it is held that – 21. The comparison between the pre amendment and post amendment of Section 36(1)(vii) shows that prior to the amendment the assessee was required to establish that the debt in question had become bad in the previous year ... assessee to prove that the debt written off by him is indeed bad debt for the purpose of allowing it under Section 36(1)(vii). The assessee therein had claimed writing of bad debt in the sum of Rs.4,59,60,393/-. The contention of the assessee was that

M/S. Bengal Omnitech Nirman Ltd., Kolkata vs. A.C.I.T./I.T.O., Ward - 8(1), Kolkata

In the result, the appeal of the assessee is allowed

ITA 1551/KOL/2024[2018-2019]Status: DisposedITAT Kolkata02 Dec 2025AY 2018-2019

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm

For Appellant: S/Shri S.M. Surana &For Respondent: Shri Pankaj Pandey, DR
Section 36(1)(vii)

trading loss need not necessarily be a bad debt. There, may be a bad debt which may not fall within the purview of section 36(1)(vii) of the Act, by may well be regarded as one eligible for deduction incurred in the course of carrying on business will come

Income Tax Officer, New Libra Kothi, Railway Road, Sirhind vs. Bhagwan Dass, Amloh Road, Mandi Gobindgarh

In the result, appeal of the Revenue is dismissed

ITA 1025/CHANDI/2024[2021-22]Status: DisposedITAT Chandigarh27 Nov 2025AY 2021-22
For Respondent: Shri Tej Mohan Singh, Advocate
Section 115BSection 133(6)Section 143(1)Section 36(1)Section 36(1)(vii)Section 68

case the Ld. CIT(A) is correct in allowing the assessee's claim of GST paid of Rs.12,38,488/- under section 36(1)(vii) of the Act, 1961 which was disallowed by the AO. 3. Whether on the facts and in the circumstances of the case ... Officer held that such payment represented the liability of third parties and was neither a business expense of the assessee nor allowable under section 36(1) (vii). Additionally, the AO noted that the assessee's method of accounting for GST excluded GST from purchases and sales; hence, claiming

Arkay Energy (Rameswarm) Private Limited, Hyderabad vs. DCIT., Circle-1(1), Hyderabad

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

ITA 1562/HYD/2025[2017-18]Status: DisposedITAT Hyderabad26 Nov 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं / Ita No.1562/Hyd/2025 (निर्धारण वर्ष/Assessment Year:2017-18) M/S. Arkay Energy (Rameswarm) Pvt. Ltd., Hyderabad. Vs. Dy. Commissioner Of Income Tax, Circle 1(1), Hyderabad. Pan: Aafca0044C (Appellant) (Respondent) निर्धारिती द्वारा / Assessee By: Shri P. Murali Mohan Rao, C.A. राजस्व द्वारा / Revenue By: Shri Ranjan Agrawala, Sr-Dr सुनवाई की तारीख /Date Of Hearing: 20/11/2025 घोषणा की तारीख / Pronouncement: 26/11/2025 आदेश/Order Per Vijay Pal Rao: This Appeal By The Assessee Is Directed Against The Order Dated 23.07.2025 Of National Faceless Appeal Centre (Nfac), Delhi For The

For Appellant: Shri P. Murali Mohan Rao, C.AFor Respondent: Shri Ranjan Agrawala, SR-DR
Section 143(3)Section 147Section 148Section 148ASection 151ASection 250

आयकर अपीलीय अधिकरण, हैदराबाद पीठ IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘A’ Bench, Hyderabad श्री विजय पाल राव, उपाध्यक्ष

Gbt India Private Limited, New Delhi vs. ACIT, OSD, Delhi

In the result, the assessee’s appeal is allowed as above

ITA 1764/DEL/2022[2018-19]Status: DisposedITAT Delhi26 Nov 2025AY 2018-19

Bench: Shri Challa Nagendra Prasad & Shri Avdhesh Kumar Mishra

Section 143(3)Section 234ASection 36(1)(vii)Section 36(2)

written off, amounting to Rs.15,912,680/-, despite the fact that the twin conditions for allowance of deduction of bad debts contained in Section 36(1)(vii) read with Section 36(2) of the Act are satisfied 8. That, on the facts and circumstances of the case ... debts written off out of the provision made for doubtful debts. 49. The Ld. Counsel submitted that the claim of the requirements of section 36(1)(vii) of the Act stood fulfilled since the entire amount of Rs.12,92,586/- representing provision made during the year was added back

DCIT 2(3)(2), Mumbai vs. Icici Bank Ltd, Mumbai

In the result, ground no. 3 of appeal of

ITA 1550/MUM/2016[2009-10]Status: DisposedITAT Mumbai21 Nov 2025AY 2009-10

Bench: Shri Pawan Singh & Shri Girish Agrawal(Physical Hearing) Icici Bank Limited, Dcit, 2(3)(2), Mumbai, Icici Bank Towers, North East Wing, Vs Aayakarbhavan, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue (Physical Hearing) Dcit, 2(3)(2), Mumbai, Icici Bank Limited Aayakar Bhavan, Vs Icici Bank Towers, North East Wing, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue

Section 10(15)Section 14ASection 254(1)Section 92CSection 92C(3)(c)

viia) claimed as per original return for A.Y. 2007-08 filed on September 30, 2008) 2020,64,57,169/- Bad debts claimed under section 36(1)(vii)of the Act 27. The bad debts claim of the assessee consists of bad debts written off on retail and corporate portfolio ... taking view that in earlier years similar claim was disallowed.it was also held that the assessee has not satisfied the condition of section 36(1)(vii) that the assessee failed to prove that the debts have become bad. On appeal before ld CIT(A) entire claim of the assessee

Icici Bank Ltd, Mumbai vs. DCIT 2(3)(2), Mumbai

In the result, ground no. 3 of appeal of

ITA 4418/MUM/2015[2009-10]Status: DisposedITAT Mumbai21 Nov 2025AY 2009-10

Bench: Shri Pawan Singh & Shri Girish Agrawal(Physical Hearing) Icici Bank Limited, Dcit, 2(3)(2), Mumbai, Icici Bank Towers, North East Wing, Vs Aayakarbhavan, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue (Physical Hearing) Dcit, 2(3)(2), Mumbai, Icici Bank Limited Aayakar Bhavan, Vs Icici Bank Towers, North East Wing, 1St Floor, Bandrakurla Complex, Mumbai – 400020. Bandra (East), Mumbai – 400051. [Pan No. Aaaci1195H] Appellant / Assessee Respondent / Revenue

Section 10(15)Section 14ASection 254(1)Section 92CSection 92C(3)(c)

viia) claimed as per original return for A.Y. 2007-08 filed on September 30, 2008) 2020,64,57,169/- Bad debts claimed under section 36(1)(vii)of the Act 27. The bad debts claim of the assessee consists of bad debts written off on retail and corporate portfolio ... taking view that in earlier years similar claim was disallowed.it was also held that the assessee has not satisfied the condition of section 36(1)(vii) that the assessee failed to prove that the debts have become bad. On appeal before ld CIT(A) entire claim of the assessee

Star Paper Mills Limited, Kolkata vs. PCIT - 2, Kolkata

In the result, the appeal of the assessee is allowed

ITA 641/KOL/2025[2018-19]Status: DisposedITAT Kolkata20 Nov 2025AY 2018-19

Bench: SHRI RAJESH KUMAR, ACCOUNTANT MEMBER SHRI PRADIP KUMAR CHOUBEY (Judicial Member)

Section 143(2)Section 143(3)Section 263Section 36(1)(vii)

amount of debts/advances and therefore the provision account stood obliterated, would tantamount to actual write off for the purposes of claiming deduction under Section 36(1)(vii) of Act. The ld AR also relied on the following decisions wherein the Courts allowed the deduction for provision for bad & doubtful debts

Bk Garden Fresh Private Ltd., Kolkata vs. ITO, Ward 7(1), Kolkata

In the result, the appeal of the assessee is allowed on the two issues as discussed above and allowed on the third issue for statistical purposes

ITA 545/KOL/2025[2017-18]Status: DisposedITAT Kolkata18 Nov 2025AY 2017-18

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyassessment Year: 2017-18 Bk Garden Fresh Pvt. Ltd.……………………………………….……….……Appellant 12, Ramlochan Mullick Street, Kol-700007. [Pan: Aafcb6953P] Vs. Ito, Ward-7(1), Kolkata..………………………………….....……...…..…..Respondent Appearances By: Shri N. S. Saini, Ar & Satyaki Mondal, Ca, Appeared On Behalf Of The Appellant. Shri Subrata Aich, Sr. Dr, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 15, 2025 Date Of Pronouncing The Order : November 18, 2025 Order Per Pradip Kumar Choubey: This Appeal Filed By The Assessee Is Directed Against The Order Dated 10.02.2025 Of The National Faceless Appeal Centre [‘Cit(A)’] Passed Under Section 250 Of The Income-Tax Act, 1961 (Hereinafter Referred To As “The Act”) For The Assessment Year 2017–18. 2. Brief Facts Of The Case Are That The Assessee Filed Return Of Income Declaring Total Income Of Rs.10,31,194/-. The Case Of The Assessee Was Selected For Complete Scrutiny Specifically On The Ground Of Large Cash Deposits During Demonetisation Period. Notices U/S 143(2) & 142(1) Along With Questionnaire Were Issued & After Considering The Submissions & Details Submitted By The Assessee, The Assessing Officer Assessed Total Income At Rs.90,47,322/- After Making The Following Additions: Bk Garden Fresh Pvt. Ltd 1. Bad Debts Rs.90,006/- 2. Cash Discount Rs.95,622/- 3. Charity & Donation Rs.50,500/- 4. Disallowed On Cash Deposits At Rs.77,80,000/- U/S 69A

Section 143(2)Section 250Section 36(1)(vii)Section 69A

आयकर अपील"य अ"धकरण, कोलकाता पीठ, कोलकाता IN THE INCOME TAX APPELLATE TRIBUNAL “A” BENCH KOLKATA Before Shri Rajesh

Asst.Commissioner of Income Tax(It)-2(1)-2, Mumbai vs. Dbs Bank Limited, Mumbai

In the result, appeal of the assessee is allowed

ITA 2430/MUM/2025[2017-18]Status: DisposedITAT Mumbai18 Nov 2025AY 2017-18

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 28Section 36(1)(vii)Section 37(1)

loan, the unrecoverable portion was written off in the accounts as irrecoverable. The statutory requirement for allowance of bad debt under section 36(1)(vii) read with section 36(2) thus stands fulfilled. The character of the loss is not altered merely because the erosion becomes evident on the date

Asst. Commissioner of Income Tax, Mumbai vs. Dbs Bank Limited, Mumbai

In the result, appeal of the assessee is allowed

ITA 2429/MUM/2025[2016-17]Status: DisposedITAT Mumbai18 Nov 2025AY 2016-17

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI PRABHASH SHANKAR (Accountant Member)

Section 143(3)Section 28Section 36(1)(vii)Section 37(1)

loan, the unrecoverable portion was written off in the accounts as irrecoverable. The statutory requirement for allowance of bad debt under section 36(1)(vii) read with section 36(2) thus stands fulfilled. The character of the loss is not altered merely because the erosion becomes evident on the date

Deputy Commissioner of Income Tax, Tiruchirapalli vs. The Karur Vysya Bank Limited, Karur

ITA 1889/CHNY/2025[2018]Status: DisposedITAT Chennai17 Nov 2025

Bench: Shri Aby T Varkey & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1502/Chny/2025 "नधा%रण वष% / Assessment Year: 2018-19 Karur Vysya Bank, Dcit, Erode Road, Vs. Circle-1, Karur – 639 002. Trichy. [Pan:Aaact-3373-J] (अपीलाथ'/Appellant) (()यथ'/Respondent) आयकर अपील सं./Ita No.:1889/Chny/2025 "नधा%रण वष% / Assessment Year: 2018-19 Dcit, Karur Vysya Bank, Circle-1, Vs. Erode Road, Trichy. Karur – 639 002. [Pan:Aaact-3373-J] (अपीलाथ'/Appellant) (()यथ'/Respondent) Assessee By : Shri. S. Ananthan, C.A. & Ms. R. Lalitha, C.A. Department By : Ms. E. Pavuna Sundari, C.I.T. सुनवाई क* तार"ख/Date Of Hearing : 03.09.2025 घोषणा क* तार"ख/Date Of Pronouncement : 17.11.2025 आदेश /O R D E R Per S. R. Raghunatha, Am :

For Appellant: Shri. S. Ananthan, C.A. &For Respondent: Ms. E. Pavuna Sundari, C.I.T
Section 115JSection 142(1)Section 143(2)Section 143(3)Section 36(1)(vii)Section 36(1)(viia)Section 41(4)

Appellant bank. 3.1. The lower authorities failed to appreciate the fact that the non-rural debts are not controlled by the proviso to Section 36(1)(vii). 3.2. The lower authorities erred in not following the decisions of the Hon’ble Supreme Court in the case of Catholic Syrian Bank ... lower authorities failed to appreciate the fact that introduction of Explanation 2 to Section 36(1)(vii) by Finance Act, 2013 has not changed the proposition of law as it existed before introduction of such explanation. 3.4. The lower authorities failed to appreciate the fact that this issue is covered

M/S. Karur Vysya Bank, Karur vs. DCIT, Circle-1, Trichy

ITA 1502/CHNY/2025[2018-19]Status: DisposedITAT Chennai17 Nov 2025AY 2018-19

Bench: Shri Aby T Varkey & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:1502/Chny/2025 "नधा%रण वष% / Assessment Year: 2018-19 Karur Vysya Bank, Dcit, Erode Road, Vs. Circle-1, Karur – 639 002. Trichy. [Pan:Aaact-3373-J] (अपीलाथ'/Appellant) (()यथ'/Respondent) आयकर अपील सं./Ita No.:1889/Chny/2025 "नधा%रण वष% / Assessment Year: 2018-19 Dcit, Karur Vysya Bank, Circle-1, Vs. Erode Road, Trichy. Karur – 639 002. [Pan:Aaact-3373-J] (अपीलाथ'/Appellant) (()यथ'/Respondent) Assessee By : Shri. S. Ananthan, C.A. & Ms. R. Lalitha, C.A. Department By : Ms. E. Pavuna Sundari, C.I.T. सुनवाई क* तार"ख/Date Of Hearing : 03.09.2025 घोषणा क* तार"ख/Date Of Pronouncement : 17.11.2025 आदेश /O R D E R Per S. R. Raghunatha, Am :

For Appellant: Shri. S. Ananthan, C.A. &For Respondent: Ms. E. Pavuna Sundari, C.I.T
Section 115JSection 142(1)Section 143(2)Section 143(3)Section 36(1)(vii)Section 36(1)(viia)Section 41(4)

Appellant bank. 3.1. The lower authorities failed to appreciate the fact that the non-rural debts are not controlled by the proviso to Section 36(1)(vii). 3.2. The lower authorities erred in not following the decisions of the Hon’ble Supreme Court in the case of Catholic Syrian Bank ... lower authorities failed to appreciate the fact that introduction of Explanation 2 to Section 36(1)(vii) by Finance Act, 2013 has not changed the proposition of law as it existed before introduction of such explanation. 3.4. The lower authorities failed to appreciate the fact that this issue is covered

DCIT, Circle - 19(1), Delhi vs. Punjab National Bank, Maharashtra

In the result, appeal of assessee in ITA No

ITA 3039/DEL/2024[2020-21]Status: DisposedITAT Delhi17 Nov 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri K. Sampath, AdvFor Respondent: Shri Jitender Singh, CIT-DR
Section 115JSection 36(1)Section 36(1)(via)Section 36(1)(vii)Section 36(1)(viia)

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘A’ BENCH, NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER, AND SHRI

Punjab National Bank, Delhi vs. DCIT, Circle-19(1), Delhi

In the result, appeal of assessee in ITA No

ITA 2712/DEL/2024[2020-21]Status: DisposedITAT Delhi17 Nov 2025AY 2020-21

Bench: Shri Satbeer Singh Godara & Shri Naveen Chandra

For Appellant: Shri K. Sampath, AdvFor Respondent: Shri Jitender Singh, CIT-DR
Section 115JSection 36(1)Section 36(1)(via)Section 36(1)(vii)Section 36(1)(viia)

IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI ‘A’ BENCH, NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER, AND SHRI

ACIT, Circle-1(1), New Delhi, C.R. Building vs. Aircom International India Pvt Ltd, Delhi

The appeal of the Revenue is dismissed

ITA 3096/DEL/2023[2014-15]Status: DisposedITAT Delhi14 Nov 2025AY 2014-15

Bench: Shri S. Rifaur Rahman & Shri Anubhav Sharmaassessment Year : 2014-15 Dcit, Vs. M/S Aircom International India Pvt. Ltd., Circle-1(1), M-12, Balrama House, New Delhi. Karampura Complex, Opp. Milan Cinema, Karam Pura West Delhi Delhi – 110 015. Pan: Aadca0915A (Appellant) (Respondent) Assessee By : Shri Salil Kapoor, Advocate; Ms Ananya Kapoor, Advocate; & Shri Shivam Yadav, Advocate. Revenue By : Shri Ajay Kumar Arora, Sr. Dr Date Of Hearing : 06.11.2025 Date Of Pronouncement : 14.11.2025 Order

For Appellant: Shri Salil Kapoor, AdvocateFor Respondent: Shri Ajay Kumar Arora, Sr. DR
Section 143(3)Section 250(4)Section 36(1)(vii)Section 36(2)Section 37(1)

observed as follows; “Ground no 3 is against Disallowance of Bad Debts amounting to Rs.1,26,71,902 under section 36(1)(vii) read with section 36(2) of the Act. During the assessment proceedings it was seen that the assessee has claimed trade receivables written off under the head

The Sullurpet Farmers Service Co Operative Society Limited, Nellore vs. Income Tax Officer, Ward-1, Gudur

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

ITA 1346/HYD/2024[2017-18]Status: HeardITAT Hyderabad12 Nov 2025AY 2017-18

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1346/Hyd/2024 (िनधा"रण वष"/Assessment Year 2017-2018) The Sullurpet Farmers Service Co-Operative Society Limited, The Income Tax Officer, Sullurpeta – 524 121. Vs. Ward-1, Gudur. Nellore District. Pin – 524 101. Pan Aacat7587J (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Harsha राज" व "ारा /Revenue By: Sri Rakesh Chintagumpula, Sr. Ar

For Appellant: CA HarshaFor Respondent: Sri Rakesh Chintagumpula, Sr. AR
Section 144Section 80P

incorrectly held that the Appellant was ineligible to claim a deduction for bad and doubtful debts under section 36(1)(vii) and 36(2), due to alleged non-compliance with the relevant conditions. 6. The Ld. CIT(A) has erred in upholding the order passed by AO and imputing interest

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

In the result, the appeal of the Revenue is dismissed

ITA 5521/MUM/2025[2016-17]Status: DisposedITAT Mumbai12 Nov 2025AY 2016-17

Bench: Shri Vikram Singh Yadav & Shri Anikesh Banerjeeassessment Year : 2016-17 Dcit, Circle-2(1)(1), Central Bank Of India, Room No. 561, 5Th Floor, Mumbai Main Office, Aayakar Bhavan, Vs. M.G. Road, Fort, Mumbai-400020. Greater Bombay, Mumbai-400023. Pan : Aaacc2498P (Appellant) (Respondent) For Assessee : Shri Nitesh Joshi For Revenue : Shri Virabhadra S. Mahajan, Sr.Dr Date Of Hearing : 10-11-2025 Date Of Pronouncement : 12-11-2025 O R D E R

For Appellant: Shri Nitesh JoshiFor Respondent: Shri Virabhadra S. Mahajan, Sr.DR
Section 115Section 115JSection 143(3)Section 271(1)(c)Section 36(1)(vii)

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI “C” BENCH : MUMBAI BEFORE SHRI VIKRAM SINGH YADAV, ACCOUNTANT MEMBER AND SHRI ANIKESH

Monotech Systems Ltd., Chennai vs. DCIT, Corp. Circle-4(1), Chennai

In the result, the appeal of the assessee is allowed

ITA 1021/CHNY/2025[2017]Status: DisposedITAT Chennai11 Nov 2025

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

For Appellant: Shri. J. Prabhakar, F.C.AFor Respondent: Ms. R. Anitha, Addl. C.I.T
Section 147Section 234BSection 36Section 37(1)Section 45

आयकर अपील"य अ"धकरण, ‘सी’ "यायपीठ, चे"नई IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH, CHENNAI "ी मनु कुमार

Shri Rajkot District Co-Operative Bank Ltd., Rajkot vs. The Deputy Commissioner of Income-Tax, Circle - 1(2), 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)

claimed deductions in respect of these provisions u/s 36(1)(viia). 16. Though the Ld.PCIT, above, has drawn parity between the provisions of section 36(1)(vii) and section 36(1)(viia) of the Page 11 of 33 Rajkot Dist. Co-op. Bank Ltd. Act, to hold that the principle