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2018 (10) TMI 1492 - AT - Income TaxInterest on share capital paid to the members of the Bank - Held that:- As observed from the order of the AO that the interest on share capital was related to the year 2010-11 which is relevant for the assessment year 2011-12, but not the impugned year. Neither the CIT(A) nor the AO has given a clear finding with regard to the correct assessment year in which the interest was accrued. Therefore, we remit the matter back to the file of the AO to examine the issue with regard to the accrual of liability as per the system of accounting followed by the assessee and decide the issue afresh on facts and merits. The appeal of the revenue on this issue is allowed for statistical purpose. Provision for bad debts under the head ‘provision for standard assets’ - AR submitted that the said amount was not representing the provision for standard assets, it was in fact a bad debt, incurred over and above the provision made by the assessee u/s 36(1)(viia) - Held that:- It appears from the discussion of the AO as well as the Ld.CIT(A) that the issue was not properly verified by the lower authorities. The assessee also did not furnish the required information before the lower authorities. It was also not clear, whether the assessee has claimed the said deduction u/s 36(1)(viia) or not. Therefore, we are of the considered opinion that the issue needs detailed verification, hence, in the interest of justice, we remit the matter back to the file of the AO to examine the issue in detail and decide the issue afresh on merits after giving due opportunity to the assessee. Accordingly, this ground of the assessee in CO is allowed for statistical purpose.
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