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2017 (9) TMI 106 - ITAT DELHIDeduction under section 36(1)(viia) - provision for bad and doubtful debts - assessee claimed deduction u/s 36(1)(viia) at 10 per cent. of the average agricultural advances made by its rural branches - CIT-A allowed the claim - Held that:- In the present case, the Assessing Officer himself admitted in the assessment order at page No. 3 that the assessee had claimed deduction under section 36(1)(viia) of the Act at ₹ 105,69,80,000 which is 10 per cent. of the aggregate rural advances of the bank. The aforesaid claim was allowable to the assessee as per the ratio laid down in the aforesaid referred to cases of Southern Technologies Ltd. v. Joint CIT [2010 (1) TMI 5 - SUPREME COURT OF INDIA] and Catholic Syrian Bank Ltd. v. CIT [2012 (2) TMI 262 - SUPREME COURT OF INDIA]. The impugned order passed by the Commissioner of Income-tax (Appeals) is in consonance with the observations made by the Income-tax Appellate Tribunal "F" Bench, New Delhi having the same combination in the assessee's own case for the assessment year 2009-10 i.e., Prathma Bank v. CIT [2016 (12) TMI 56 - ITAT DELHI]. We, therefore, considering the totality of the facts as discussed hereinabove, do not see any valid ground to interfere with the findings given by the learned Commissioner of Income-tax (Appeals). - Decided against revenue.
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