THE ASSTT. CIT., CIRCLE - 2(2),, SURAT vs. THE SURAT DISTRICT CO. OPERATIVE BANK LTD.,, SURAT

In the result, appeal of assessee for A

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Physical Court) The Surat District Co- Deputy Commissioner Of Operative Bank Ltd., Income Tax, Vs Kanpith, Lalgate, Circle-2(2), Aayakar Bhavan, Surat-395003 Majura Gate, Pan : Aaaat 2985 Q Surat. Appellant / Revenue Respondent / Assessee

24. Clear legislative intent of the relevant provisions and unambiguous language of the circulars with reference to the amendments to Section 36 of the Act demonstrate that the deduction on account of provisions for bad and doubtful debts under Section 36(1)(viia) is distinct and independent of the provisions of Section 36(1)(vii) relating to allowance

ASSISTANT COMMISSIONER OF INCOME TAX, CIR.2(1)(1), SURAT vs. THE SURAT DISTRICT CO-OP. BANK LTD., SURAT

In the result, ground No.1& 3 raised by the Revenue is dismissed

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini(Hearing In Virtual Court) Assistant Commissioner The Surat District Co- Of Income Tax, Operative Bank Ltd. Vs Circle-2(1)(1), 1, Kanpith, Lalgate, Surat. Surat-395003 Pan : Aaaat 2985 Q Appellant / Revenue Respondent / Assessee

24. Clear legislative intent of the relevant provisions and unambiguous language of the circulars with reference to the amendments to Section 36 of the Act demonstrate that the deduction on account of provisions for bad and doubtful debts under Section 36(1)(viia) is distinct and independent of the provisions of Section 36(1)(vii) relating to allowance

THE SURAT DISTRICT CO-OP. BANK LTD,SURAT vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-2(2), SURAT, SURAT

In the result, ground No.6 raised by the assessee, is allowed for statistical purposes

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.590/Srt/2019 Assessment Year: (2011-12) (Physical Hearing) The Surat District Co.Op. Bank Ltd., Vs. The Acit, Circle-2(2), Shri Pramodbhai Desai Sahakar Bhavan, Surat. J. P. Road, Athwa Gate, Surat – 395001. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaat2985Q (Assessee) (Respondent) आयकर अपील सं./Ita No.4/Srt/2020 Assessment Year: (2011-12) The Dcit, Circle-2(2), Vs. The Surat District Co.Op. Bank Ltd., Surat. Shri Pramodbhai Desai Sahakar Bhavan, J. P. Road, Athwa Gate, Surat – 395001. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaat2985Q (Assessee) (Respondent)

24. Clear legislative intent of the relevant provisions and unambiguous language of the circulars with reference to the amendments to Section 36 of the Act demonstrate that the deduction on account of provisions for bad and doubtful debts under Section 36(1)(viia) is distinct and independent of the provisions of Section 36(1)(vii) relating to allowance

DCIT, CIRCLE-2(2), SURAT vs. THE SURAT DISTRICT CO-OP. BANK LIMITED, SURAT

In the result, ground No.6 raised by the assessee, is allowed for statistical purposes

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.590/Srt/2019 Assessment Year: (2011-12) (Physical Hearing) The Surat District Co.Op. Bank Ltd., Vs. The Acit, Circle-2(2), Shri Pramodbhai Desai Sahakar Bhavan, Surat. J. P. Road, Athwa Gate, Surat – 395001. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaat2985Q (Assessee) (Respondent) आयकर अपील सं./Ita No.4/Srt/2020 Assessment Year: (2011-12) The Dcit, Circle-2(2), Vs. The Surat District Co.Op. Bank Ltd., Surat. Shri Pramodbhai Desai Sahakar Bhavan, J. P. Road, Athwa Gate, Surat – 395001. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaaat2985Q (Assessee) (Respondent)

24. Clear legislative intent of the relevant provisions and unambiguous language of the circulars with reference to the amendments to Section 36 of the Act demonstrate that the deduction on account of provisions for bad and doubtful debts under Section 36(1)(viia) is distinct and independent of the provisions of Section 36(1)(vii) relating to allowance

THE ACIT, CIRCLE-1,, BHARUCH vs. BHARUCH DISTRICT CENTRAL CO. OP. BANK LTD.,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

2 of the appeal relates to deleting the disallowance of deduction of Rs. 7.500 crores provision for bad and doubtful debts under Section 36(1)(viia) against the advances of rural branches. The ld. AR of the assessee submits that the assessing officer not allowed deduction section 36(1)(viia) to the assessee by taking view that the definition

THE BHARUCH DIST.CENTRAL CO.OP.BANK LTD.,,BHARUCH vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

2 of the appeal relates to deleting the disallowance of deduction of Rs. 7.500 crores provision for bad and doubtful debts under Section 36(1)(viia) against the advances of rural branches. The ld. AR of the assessee submits that the assessing officer not allowed deduction section 36(1)(viia) to the assessee by taking view that the definition

BHARUCH DISTRICT CENTRAL CO.-OP. BANK LTD.,,BHARUCH vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX, BHAURCH RANGE,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

2 of the appeal relates to deleting the disallowance of deduction of Rs. 7.500 crores provision for bad and doubtful debts under Section 36(1)(viia) against the advances of rural branches. The ld. AR of the assessee submits that the assessing officer not allowed deduction section 36(1)(viia) to the assessee by taking view that the definition

THE BHARUCH DIST.CENTRAL CO.OP.BANK LTD.,,BHARUCH vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

2 of the appeal relates to deleting the disallowance of deduction of Rs. 7.500 crores provision for bad and doubtful debts under Section 36(1)(viia) against the advances of rural branches. The ld. AR of the assessee submits that the assessing officer not allowed deduction section 36(1)(viia) to the assessee by taking view that the definition

BHARUCH DISTRICT CENTRAL CO.-OP. BANK LTD.,,BHARUCH vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX, BHAURCH RANGE,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

2 of the appeal relates to deleting the disallowance of deduction of Rs. 7.500 crores provision for bad and doubtful debts under Section 36(1)(viia) against the advances of rural branches. The ld. AR of the assessee submits that the assessing officer not allowed deduction section 36(1)(viia) to the assessee by taking view that the definition

THE ACIT, CIRCLE-1,, BHARUCH vs. BHARUCH DISTRICT CENTRAL CO. OP. BANK LTD.,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

2 of the appeal relates to deleting the disallowance of deduction of Rs. 7.500 crores provision for bad and doubtful debts under Section 36(1)(viia) against the advances of rural branches. The ld. AR of the assessee submits that the assessing officer not allowed deduction section 36(1)(viia) to the assessee by taking view that the definition

THE ACIT, CIRCLE-1,, BHARUCH vs. BHARUCH DISTRICT CENTRAL CO. OP. BANK LTD.,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

2 of the appeal relates to deleting the disallowance of deduction of Rs. 7.500 crores provision for bad and doubtful debts under Section 36(1)(viia) against the advances of rural branches. The ld. AR of the assessee submits that the assessing officer not allowed deduction section 36(1)(viia) to the assessee by taking view that the definition

BHARUCH DISTRICT CENTRAL CO.-OP. BANK LTD.,,BHARUCH vs. THE ADDITIONAL COMMISSIONER OF INCOME TAX, BHAURCH RANGE,, BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

2 of the appeal relates to deleting the disallowance of deduction of Rs. 7.500 crores provision for bad and doubtful debts under Section 36(1)(viia) against the advances of rural branches. The ld. AR of the assessee submits that the assessing officer not allowed deduction section 36(1)(viia) to the assessee by taking view that the definition

DEPUTY COMMISSIONER OF INCOME TAX, CIR-2(1)(1), BARODA vs. THE BHARUCH DIS CENT CO-OP BANK LTD., BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

2 of the appeal relates to deleting the disallowance of deduction of Rs. 7.500 crores provision for bad and doubtful debts under Section 36(1)(viia) against the advances of rural branches. The ld. AR of the assessee submits that the assessing officer not allowed deduction section 36(1)(viia) to the assessee by taking view that the definition

DEPUTY COMMISSIONER OF INCOME TAX, CIR-2(1)(1), BARODA vs. THE BHARUCH DIS CENT CO-OP BANK LTD., BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

2 of the appeal relates to deleting the disallowance of deduction of Rs. 7.500 crores provision for bad and doubtful debts under Section 36(1)(viia) against the advances of rural branches. The ld. AR of the assessee submits that the assessing officer not allowed deduction section 36(1)(viia) to the assessee by taking view that the definition

DEPUTY COMMISSIONER OF INCOME TAX, CIR-2(1)(1), BARODA vs. THE BHARUCH DIS CENT CO-OP BANK LTD., BHARUCH

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

2 of the appeal relates to deleting the disallowance of deduction of Rs. 7.500 crores provision for bad and doubtful debts under Section 36(1)(viia) against the advances of rural branches. The ld. AR of the assessee submits that the assessing officer not allowed deduction section 36(1)(viia) to the assessee by taking view that the definition