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2016 (4) TMI 753 - AT - Income TaxRevision u/s 263 - CIT(A) restricting claim u/s 36( 1)(viia)only for provision for rural debts and consequently disallowing claim for deduction of provision made of in accordance with the provision of sec 36( I )(viia) - whether deduction u/s.36(1)(vii) and 36(1)(viia) shall be in respect of both bad and doubtful debts irrespective of rural or urban debts? - Held that:- The legislative intention of decision of Catholic Syrian Bank [2012 (2) TMI 262 - SUPREME COURT OF INDIA ] was to protect the rural farmers and also benefit given without actual write off in the actual Books of Accounts though the principle was considered in the earlier years and the Department has accepted and passed the order. On the decision of the allowability of Sec.36(1)(viia) we relied on the Co-ordinate decision of Lakshmi Vilas Bank [2016 (4) TMI 572 - ITAT CHENNAI] the provision has been restricted to the extent of rural branches only. We confirm the findings of the Commissioner of Income Tax on the issue of rural branches following the Catholic Syrian Bank decision and uphold the order of the Commissioner of Income Tax - Decided against assessee
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